the u.s. environmental protection agency (epa) proposes to ... · technical contact: patty mcgrath,...
TRANSCRIPT
![Page 1: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/1.jpg)
NPDES Permit Number ID-002540-2 Date June 8 2000 Public Notice Expiration Date July 23 2000 Technical Contact Patty McGrath (206) 553-0979
1-800-424-4372 (within Region 10) mcgrathpatriciaepagov
The US Environmental Protection Agency (EPA) Proposes to Reissue a Wastewater Discharge Permit To
Thompson Creek Mining Company PO Box 62
Clayton Idaho 83227
and
the State of Idaho Proposes to Certify the Permit
EPA proposes NPDES permit reissuance EPA proposes to reissue the existing National Pollutant Discharge Elimination System (NPDES) permit to the Thompson Creek Mining Company (TCMC) The draft permit sets conditions on the discharge of pollutants from the Thompson Creek Mine facilities to Thompson Creek Squaw Creek and the Salmon River In order to ensure protection of water quality and human health the permit places limits on the types and amounts of pollutants that can be discharged
This Fact Sheet includes - information on public comment public hearing and appeal procedures - a description of the current discharges - a listing of proposed effluent limitations and other conditions - a map and description of the discharge locations - background information supporting the conditions in the draft permit
The State of Idaho proposes certification The Idaho Division of Environmental Quality (IDEQ) proposes to certify the NPDES permit for the TCMC under section 401 of the Clean Water Act The state submitted a preliminary 401 certification prior to the public notice which is incorporated in the draft permit
Public comment on the draft permit Persons wishing to comment on or request a public hearing for the draft permit may do so in writing by the expiration date of the public notice A request for a public hearing must state the nature of the issues to be raised as they relate to the permit as well as the requesterrsquos name address and telephone number All comment and requests for public hearings must be in writing and submitted to EPA as described in the Public Comments section of the attached public notice After the public notice expires and all substantive comments have been considered EPArsquos regional Director for the Office of Water will make a final decision regarding permit reissuance
If no substantive comments are received the tentative conditions in the draft permit will become final and the permit will become effective upon issuance If comments are received EPA will address the comments and issue the permit The permit will become effective 30 days after the issuance date unless a request for an evidentiary hearing is submitted within 30 days
Public comment on the State preliminary 401 certification The Idaho Division of Environmental Quality (IDEQ) provides the public with the opportunity to review and comment on preliminary 401 certification decisions Any person may request in writing that IDEQ provide that person notice of IDEQrsquos preliminary 401 certification decision including where appropriate the draft certification Persons wishing to comment on the preliminary 401 certification should submit written comments by the public notice expiration date to the Idaho Division of Environmental Quality (IDEQ) Idaho Falls Regional Office 900 N Skyline Idaho Falls ID 83402
Documents are available for review The draft NPDES permit and related documents can be reviewed or obtained by visiting or contacting EPArsquos Regional Office in Seattle between 830 am and 400 pm Monday through Friday (see address below)
United States Environmental Protection Agency Region 10 1200 Sixth Avenue OW-130 Seattle Washington 98101 (206) 553-0523 or 1-800-424-4372 (within Alaska Idaho Oregon and Washington)
The fact sheet and draft permit are also available at
EPA Idaho Operations Office 1435 North Orchard Street Boise Idaho 83706 (208) 378-5746
Idaho Division of Environmental Quality Idaho Falls Regional Office 900 N Skyline Idaho Falls Idaho 83402 (208) 528-2650
2
Challis Public Library Sixth and Main Challis Idaho 83226
The draft permit and fact sheet can also be found by visiting the Region 10 website at wwwepagovr10earthwaterhtm
For technical questions regarding the permit or fact sheet contact Patty McGrath at the phone numbers or email address at the top of this fact sheet Those with impaired hearing or speech may contact a TDD operator at 1-800-833-6384 (ask to be connected to Patty McGrath at the above phone numbers) Additional services can be made available to person with disabilities by contacting Patty McGrath
3
TABLE OF CONTENTS
LIST OF ACRONYMS 5
I APPLICANT 6
II FACILITY ACTIVITY 6
III FACILITY BACKGROUND 7 A Permit History 7 B Compliance History 8
IV RECEIVING WATERS 8
V EFFLUENT LIMITATIONS 9
VI MONITORING REQUIREMENTS 13 A Effluent Monitoring 13 B Whole Effluent Toxicity Testing 15 C Storm Water Monitoring 15 D Receiving Water Monitoring 16 E Representative Sampling 18
VII OTHER PERMIT CONDITIONS 18 A Quality Assurance Plan 18 B Best Management Practices Plan 19 C Additional Permit Provisions 19
VIII OTHER LEGAL REQUIREMENTS 19 A Endangered Species Act 19 B State Certification 20 C Antidegradation 21 D Permit Expiration 21
APPENDIX A - FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
APPENDIX D - EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
APPENDIX E - ENDANGERED SPECIES ACT CONSULTATION
APPENDIX F - REFERENCES
4
LIST OF ACRONYMS
AML Average Monthly Limit
BAT Best Available Technology Economically Achievable BCT Best Conventional Pollutant Control Technology BMP Best Management Practices BPT Best Practicable Control Technology
CFR Code of Federal Regulations cfs cubic feet per second CV coefficient of variation CWA Clean Water Act
DMR Discharge Monitoring Report
EPA Environmental Protection Agency
IDEQ Idaho Division of Environmental Quality
LA left abutment wastewater
MDL maximum daily limit mgd million gallons per day MZ mixing zone
NPDES National Pollutant Discharge Elimination System NTR National Toxics Rule
PBS pumpback system wastewater PIT pit wastewater
RP Reasonable Potential RPM Reasonable Potential Multiplier
TCM Thompson Creek Mine TCMC Thompson Creek Mining Company tpd tons per day TSD Technical Support Document (EPA 1991) TSS Total Suspended Solids TU Toxic Unit (TUa = acute toxic unit TUc = chronic toxic unit)
USFS Unites States Forest Service
WET Whole Effluent Toxicity WLA Wasteload Allocation
5
I APPLICANT
Thompson Creek Mining Company NPDES Permit No ID-002540-2
Mailing Address
Facility Location
PO Box 62 Clayton Idaho 83227 See Figure A-1 in Appendix A
Facility Contact Bert Doughty Supervisor Environmental Affairs (208) 838-2200
II FACILITY ACTIVITY
The Thompson Creek Mine (TCM) is a molybdenum mine and mill located in Custer County Idaho approximately 30 miles southwest of Challis (see Figure A-1) The mine and mill are owned and operated by the Thompson Creek Mining Company (TCMC) The facility has been in operation since 1983 with periods of temporary closure in 1991 and from December 1992 to April 1994 At the current processing rate of 28000 to 32000 tpd the life of the TCM is estimated at 15 years
The mine facilities encompass approximately 2400 acres on both private lands and public lands The federal land area is managed by the US Forest Service (Salmon-Challis National Forest) and the US Bureau of Land Management (Challis Resource Area) The mine facilities are located in the Bruno Creek Buckskin Creek and Pat Hughes Creek drainages These creeks are tributaries to Thompson and Squaw creeks which flow into the Salmon River approximately 5 miles from the mine site (see Figure A-1)
Molybdenum ore is mined via open pit methods At the mill the ore is processed by flotation to produce a molybdenum concentrate The molybdenum concentrate is transported off-site for refining Tailings (the residuals from flotation) are piped in a slurry from the mill to the tailings impoundment The tailings impoundment is constructed in the upper Bruno Creek watershed and covers approximately 280 acres The impoundment currently contains approximately 90 million tons of tailings Waste rock (rock that is removed from the mine in order to gain access to the ore) is hauled from the mine for disposal in either the Pat Hughes or Buckskin waste rock dumps To-date approximately 350 million tons of waste rock have been disposed in the Buckskin Creek dump and 50 million tons in the Pat Hughes dump More detailed information on the TCM operations can be found in the Supplemental Plan of Operations (TCMC 1998)
The facility currently discharges wastewater from the Buckskin and Pat Hughes waste rock dumps through two outfalls (001 and 002) and storm water through Outfall 003 The proposed permit will allow discharge through two new outfalls (004 and 005) from the tailings impoundment in the event of excess precipitation or mine closure In addition wastewater from Outfalls 001 and 002 may be discharged instead out of Outfall 005 The parameters of concern
6
in the discharges include pH total suspended solids (TSS) and metals The following table summarizes each outfall A more detailed description of each outfall is proved in Appendix B A map of the outfall locations is provided in Appendix A (Figure A-2)
Table 1 Proposed NPDES Outfalls
Outfall Receiving Water Description of Discharge1 Flow Rate2
001 Thompson Creek seepage and runoff from the Buckskin waste rock dump
discharge generally occurs in April-July only calculated avg discharge = 12 cfs measured max discharge = 84 cfs
002 Thompson Creek seepage and runoff from the Pat Hughes waste rock dump
discharge continuous peaks in May - July calculated avg discharge = 07 cfs measured max discharge = 12 cfs
003 Squaw Creek storm water mine road runoff Bruno Creek diversion
discharge continuous peaks in May - July calculated avg discharge = 11 cfs measured max discharge = 97 cfs
004 Squaw Creek tailings impoundment seepage predicted max discharge = 13 cfs
005 Salmon River tailings impoundment seepage and open pit mine water3
predicted max discharge = 27 cfs
Footnotes 1 - See also Appendix B 2 - Flows are based on the last five years of monitoring conducted by TCMC 3 - TCMC may discharge effluent from outfalls 001 and 002 out of Outfall 005
III FACILITY BACKGROUND
A Permit History
EPA first issued a National Pollutant Discharge Elimination System (NPDES) permit for the TCM on June 10 1981 The current permit was reissued by EPA on August 1 1988 The current permit expired on August 2 1993 A timely application for renewal of the permit and for establishment of Outfall 004 was submitted to EPA on September 17 1992 A revised application for establishment of Outfall 005 was submitted on September 7 1993 A second revised application for Outfalls 001 and 002 (applying to discharge from either the original outfall locations or the Outfall 005 location) was submitted to EPA on February 22 2000 Additional information related to this permit reissuance was submitted by TCMC to EPA on September 1 1999 September 21 1999 and February 22 2000 Because the Permittee submitted a timely application for renewal the 1988 permit has been administratively extended and remains fully effective and enforceable until reissuance
7
On July 14 1994 a draft NPDES Permit for the TCM was issued for public notice The effluent limits for metals in the July 1994 draft permit were based on State of Idaho water quality criteria that were expressed as total recoverable While EPA was finalizing the permit the State of Idaho adopted new water quality criteria that express some metals as dissolved In addition a new criteria for arsenic was promulgated To accommodate these changes and the new information submitted by TCMC this new draft permit has been prepared and is being reissued for public comment
B Compliance History
TCMC submits monthly discharge monitoring reports (DMRs) to EPA summarizing the results of effluent monitoring required by the permit The following effluent limit violations were noted based on review of the past five yearsrsquo DMRs
Outfall 001 In June and July 1995 pH was reported at 91 (outside the pH limit of 6 - 9)
Outfall 002 Violations of the maximum daily effluent limits were reported in March 1999 (TSS only) May 1999 (TSS and zinc) and August 1999 (cadmium and zinc) TCMC attributed the March violation to heavy snow pack and the subsequent violations to a break in the pit diversion line located beneath the waste rock dump TCMC stopped discharging while investigating and fixing the break The diversion line has since been fixed and discharges are within the effluent limits
IV RECEIVING WATERS
As discussed in Section II the TCM outfalls discharge to Squaw Creek Thompson Creek and the Salmon River The Idaho Water Quality Standards and Wastewater Treatment Requirements designate beneficial uses for waters of the State These three waters are classified by the State of Idaho for protection of the following uses (1) agricultural water supply (2) cold water biota (3) salmonid spawning and (4) secondary contact recreation In addition the Salmon River is protected for domestic water supply and primary contact recreation and is classified as a Special Resource Water
The State water quality standards specify water quality criteria that is deemed necessary to support the use classifications These criteria may by numerical or narrative The water quality criteria applicable to the proposed permit are provided in Appendix C (Section IIIA) These criteria provide the basis for most of the effluent limits in the draft permit
Portions of Thompson Creek and the Salmon River are listed on Idahorsquos 303(d) list (a list of impaired waters compiled under Section 303(d) of the Clean Water Act) The 303(d) list identifies water bodies that do not meet or are not expected to meet water quality standards
Specifically these waters were listed as not meeting standards for
8
Thompson Creek (about three miles downstream from Outfall 002 to the confluence with the Salmon River) - sediment and metals
Salmon River (including the discharge location) - sediment and temperature
Section 303(d) of the Clean Water Act (CWA) requires States to develop a Total Maximum Daily Load (TMDL) management plan for water bodies on the 303(d) list A TMDL allocates loading capacities to point and nonpoint sources to the water body Permit limits for point sources must be consistent with applicable TMDL allocations A TMDL for Thompson Creek and this part of the Salmon River is scheduled to be completed in 2001 The General Provisions section of the draft permit contains a provision to allow EPA to reopen the permit (eg to incorporate any applicable effluent limitations and conditions which may result from final TMDLs on these receiving waters)
V EFFLUENT LIMITATIONS
EPA followed the Clean Water Act (CWA) state and federal regulations and EPArsquos 1991 Technical Support Document for Water Quality-Based Toxics Control (TSD) to develop the effluent limits in the draft permit In general the CWA requires that the effluent limit for a particular pollutant be the more stringent of either the technology-based limit or water quality-based limit Appendix C provides discussion on the legal basis for the development of technology-based and water quality-based effluent limits
EPA sets technology-based limits based on the effluent quality that is achievable using readily available technology The Agency evaluates the technology-based limits to determine whether they are adequate to ensure that water quality standards are met in the receiving water If the limits are not adequate EPA must develop additional water quality-based limits Water quality-based limits are designed to prevent exceedances of the Idaho water quality standards in the receiving waters
The proposed permit includes technology-based limits for total suspended solids (TSS) water quality-based and technology-based limits for pH and water quality-based limits for most metals Tables 2 and 3 compare the existing effluent limits for outfalls 001 and 002 with the proposed effluent limits in the draft permit Tables 4 and 5 include the proposed effluent limits for the new discharges from outfalls 004 and 005 Appendix C describes in detail how the effluent limits were developed
Two sets of limits (tiered limits) were developed for outfalls 001 002 and 004 to allow for seasonal variability of the flows in the receiving waters Except for pH and TSS the proposed effluent limits are expressed in terms of both mass (poundsday) and concentration (ugl) for outfalls 004 and 005 Establishment of mass-based limits ensures that total loadings to the receiving waters are controlled Mass limits were not calculated for outfalls 001 and 002 since the effluent flow from these outfalls is dependent upon precipitation and varies with the
9
receiving water flow Concentration-based limits for these outfalls were calculated based on the ratio of effluent flow to receiving water flow (the dilution ratio) for each flow tier Therefore mass loadings for these outfalls will be controlled by limiting the dilution ratio consistent with the dilution ratio used to develop the concentration-based effluent limits (see also Section IV of Appendix C)
Effluent limits were not developed for Outfall 003 Rather ldquobest management practicesrdquo (BMPs) and monitoring are the permit conditions used to address storm water (see Sections VIC and VIIB of this fact sheet)
Table 2 Effluent Limitations for Outfall 001
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1 none -shy -shy 0011 0011 0092 0092
arsenic ugl 490 -shy -shy -shy ndash ndash
cadmium ugl 532 ndash 35 24 68 47
copper ugl 2452 -shy 270 180 31 21
lead ugl 5892 -shy 94 64 19 13
mercury ugl 022 -shy 046 032 0073 0050
selenium ugl -shy -shy 1505 1105 425 305
zinc ugl 1652 -shy 1500 750 210 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals are to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
10
Table 3 Effluent Limitations for Outfall 002
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1
none -shy -shy 0085 0085 018 018
arsenic ugl 490 -shy -shy -shy -shy -shy
cadmium ugl 532 ndash 11 78 52 35
copper ugl 2452 -shy 53 36 22 15
lead ugl 5892 -shy 31 21 12 83
mercury ugl 022 -shy 0077 0053 0047 0032
selenium ugl -shy -shy 235 165 175 115
zinc ugl 1652 -shy 290 200 220 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
11
Table 4 Effluent Limitations for Outfall 004
Parameter units Proposed Effluent Limitations1
at Squaw Creek flow lt 50 cfs2 at Squaw Creek flow $ 50 cfs2
Maximum Daily Monthly Average Maximum Daily Monthly Average
cadmium ugl 12 58 26 13
lbday 0084 0041 018 0091
chromium ugl 40 20 -shy -shy
lbday 028 014 -shy -shy
copper ugl 48 24 120 58
lbday 034 017 084 041
lead ugl 37 18 21 10
lbday 026 013 015 0070
mercury ugl 0037 0018 021 010
lbday 000026 000013 00015 000070
silver ugl -shy -shy 22 11
lbday -shy -shy 015 0077
zinc ugl 290 140 860 430
lbday 20 098 60 30
TSS mgl 30 20 30 20
pH su within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be total 2 - The flow tiers are representative of flow upstream of the outfall
12
Table 5 Effluent Limitations for Outfall 005
Parameter units Proposed Effluent Limitationss
Maximum Daily Monthly Average
cadmium ugl 12 62
lbday 017 0090
copper ugl 120 59
lbday 17 086
lead ugl 21 10
lbday 030 015
mercury ugl 061 030
lbday 00089 00044
silver ugl 12 60
lbday 017 0087
zinc ugl 1000 500
lbday 15 73
TSS mgl 30 20
pH su within the range of 65 - 90
Footnote 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total
VI MONITORING REQUIREMENTS
Section 308 of the Clean Water Act and federal regulation 40 CFR 12244(i) require that monitoring be included in permits to determine compliance with effluent limitations Monitoring may also be required to gather data for future effluent limitations or to monitor effluent impacts on receiving water quality TCMC is responsible for conducting the monitoring and reporting the results to EPA on monthly DMRs and in annual reports This section describes the monitoring requirements in the draft permit
A Effluent Monitoring
The effluent monitoring requirements in the draft permit are summarized in Table 6 The monitoring frequency for outfalls 001 and 002 is the same as included in the current permit (monthly for most parameters) The monitoring frequency for most of the outfall 004 and 005
13
parameters is weekly More frequent monitoring and composite sampling was determined to be necessary for these outfalls due to the composition of the outfalls (process water) the more continuous nature of the discharges and the Special Resource status of the Salmon River (Outfall 005) Flow monitoring of the receiving waters is required for outfalls 001 002 and 004 to determine which set of tiered effluent limits apply and to calculate dilution ratios (outfalls 001 and 002 only) Monitoring of Outfall 003 is discussed in Section VIC below
Some of the water quality-based effluent limits in the draft permit are close to the capability of current analytical technology to detect andor quantify (close to method detection limits) To address this concern the draft permit contains a provision requiring TCMC to use analytical methods that can achieve a method detection limit less than the effluent limitation Method detection limits are the minimum levels that can be accurately detected by current analytical technology
Table 6 Effluent Monitoring Requirements
Parameter Outfalls 001 and 002 Outfalls 004 and 005
frequency sample type frequency sample type
dilution ratio daily calculation -shy -shy
outfall flow cfs continuous recording continuous recording
metals with effluent limits1 ugl monthly grab weekly 24-hour composite
molybdenum ugl quarterly grab quarterly 24-hour composite
selenium2 ugl monthly grab quarterly 24-hour composite
TSS mgl weekly grab weekly 24-hour composite
pH standard units (su) weekly grab daily grab
hardness as CaCO3 mgl monthly grab weekly 24-hour composite
temperature oC weekly grab weekly grab
Acute WET3 TUa annually grab annually 24-hour composite
Chronic WET3 TUc annually grab quarterly 24-hour composite
Thompson Creek Flow4 cfs daily recording daily recording
Squaw Creek Flow5 cfs daily recording daily recording
Footnotes 1 - metals to be measured include cadmium chromium (outfall 004 only) copper lead mercury selenium (outfalls 001 and 002 only) silver (outfalls 004 and 005 only) and zinc 2 - selenium monitoring required for outfalls 001 and 002 (see footnote 1) and 005 3 - See Section VIB below for specific information regarding the whole effluent toxicity (WET) monitoring 4 - Thompson Creek flow monitoring is required upstream of each outfalls 001 and 002 5 - Squaw Creek flow monitoring is required upstream of Outfall 004
14
B Whole Effluent Toxicity Testing
Whole effluent toxicity (WET) is defined as the aggregate toxic effect of an effluent measured directly by an aquatic toxicity test WET tests are standardized laboratory tests that measure the total toxic effect of an effluent by exposing organisms to the effluent and noting the effects There are two different durations of toxicity tests acute and chronic Acute toxicity tests measure the test organisms survival over a 96-hour test exposure period Chronic toxicity tests measure reductions in survival growth and reproduction over a 7-day exposure
TCMC has conducted limited WET testing on their effluents In 1993 one set of WET tests were performed on effluent from outfalls 001 and 002 and some of the sources of wastewater to outfalls 004 and 005 (LA and PBS wastewaters) Results indicated no acute toxicity Chronic toxicity was indicated for Outfall 001 and the LA and PBS wastewaters at 100 effluent however the tests were not performed at dilutions representing the mixing zones In 1999 TCMC conducted an additional set of WET tests on outfalls 001 and 002 These tests indicated no acute toxicity Chronic toxicity was indicated for one species tested on Outfall 002
Federal regulations at 40 CFR 12244(d)(1) require that permits contain limits on WET when a discharge has reasonable potential to cause or contribute to an exceedence of a water quality standard In Idaho the relevant water quality standard states that surface waters of the State shall be free from toxic substances in concentrations that impair designated beneficial uses (see Appendix C Table C-2) The TSD provides guidance on implementing WET testing in NPDES permits The preliminary CWA Section 401 Certification provided by IDEQ included specific WET testing requirements for this permit (see also Section VIIIB)
Because the limited amount of existing WET testing on the TCM effluents is not adequate to determine the need for WET effluent limits WET testing has been incorporated into the draft permit The draft permit requires TCMC to conduct acute WET testing annually on effluent from each outfall Chronic WET testing must be conducted annually for outfalls 001 and 002 and quarterly for outfalls 004 and 005 TCMC is required to perform the acute tests using the salmonid species Oncorhynchus mykiss (rainbow trout) and the chronic tests using both Pimephales promelas (fathead minnow) and Ceriodaphnia dubia (water fleas) Different species are used for testing to represent different aquatic phyla (fish and invertebrates) and because different species have different sensitivities The tests will be conducted at a range of dilutions that mimic the effluent-receiving water mixing conditions Results of these tests will be used to ensure that toxics in the effluent are controlled and to determine the need for future WET limits In addition the permit establishes toxicity trigger levels for each outfall (see Appendix C Section IVB ) that if exceeded trigger additional WET testing and potentially investigations to reduce toxicity
C Storm Water Monitoring
The current permit requires TCMC to monitor the receiving water upstream and downstream of the Outfall 003 sediment ponds for turbidity The monitoring is specified as weekly during
15
February through June and monthly for the other months of the year The draft permit continues this turbidity monitoring In addition the draft permit requires daily monitoring of effluent flow and monthly monitoring of Outfall 003 for metals (cadmium copper lead mercury and zinc) hardness TSS pH and temperature to ensure that water quality standards are maintained
The storm water discharge should not adversely affect water quality This assumes appropriate design and implementation of best management practices (BMPs) in lieu of numerical effluent limits The monitoring required in the draft permit along with periodic inspections are required to evaluate the effectiveness of BMPs and to provide sufficient information to determine if these discharges either cause or contribute to water quality standards exceedences Section VIIB below discusses the BMP requirements
D Receiving Water Monitoring
The current permit requires TCMC to provide for water quality monitoring in accordance with the program agreed upon by the Interagency Task Force (members of which include the USFS BLM IDEQ EPA and TCMC) TCMCrsquos current environmental monitoring program is described in the Consolidated Environmental Monitoring Program (TCMC 1999a) This program includes monitoring of the surface water sediments and aquatic biology in the receiving waters
The draft permit requires TCMC to continue this monitoring as it relates to the permitted discharges by specifying monitoring at selected locations within and around the discharge areas The water quality monitoring requirements in the draft permit are for the most part consistent with TCMCrsquos Consolidated Monitoring Program However some additional monitoring has been added since two new outfalls are proposed (004 and 005) one of the new outfalls (005) discharges to a Special Resource Water and to verify that bioaccumulation is not of concern The following summarizes the monitoring requirements in the draft permit
Surface Water Quality Monitoring Surface water quality monitoring of the receiving waters is required four times per year upstream and downstream of each outfall for the parameters listed in Table 7 When there is a discharge from outfalls 004 or 005 the permit requires that the monitoring frequency for metals in the Salmon River be increased to monthly This was a requirement of IDEQrsquos preliminary CWA Section 401 Certification for discharge into a Special Resource Water (see also Section VIIIB) IDEQ also required that for each sampling event metals concentrations in the receiving water be compared to aquatic life chronic water quality criteria If the concentrations exceed the criteria then future sampling for that parameter will be expanded to determine 4-day average concentrations (since chronic criteria are expressed as 4shyday average concentrations)
The receiving water quality monitoring data is used to evaluate the water quality impacts of the NPDES discharges The data will also be used during the next permitting cycle to determine the need for incorporating and retaining water quality-based effluent limits into the permit In order to perform these evaluations it is necessary that the ambient monitoring use analytical methods
16
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 2: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/2.jpg)
Public comment on the draft permit Persons wishing to comment on or request a public hearing for the draft permit may do so in writing by the expiration date of the public notice A request for a public hearing must state the nature of the issues to be raised as they relate to the permit as well as the requesterrsquos name address and telephone number All comment and requests for public hearings must be in writing and submitted to EPA as described in the Public Comments section of the attached public notice After the public notice expires and all substantive comments have been considered EPArsquos regional Director for the Office of Water will make a final decision regarding permit reissuance
If no substantive comments are received the tentative conditions in the draft permit will become final and the permit will become effective upon issuance If comments are received EPA will address the comments and issue the permit The permit will become effective 30 days after the issuance date unless a request for an evidentiary hearing is submitted within 30 days
Public comment on the State preliminary 401 certification The Idaho Division of Environmental Quality (IDEQ) provides the public with the opportunity to review and comment on preliminary 401 certification decisions Any person may request in writing that IDEQ provide that person notice of IDEQrsquos preliminary 401 certification decision including where appropriate the draft certification Persons wishing to comment on the preliminary 401 certification should submit written comments by the public notice expiration date to the Idaho Division of Environmental Quality (IDEQ) Idaho Falls Regional Office 900 N Skyline Idaho Falls ID 83402
Documents are available for review The draft NPDES permit and related documents can be reviewed or obtained by visiting or contacting EPArsquos Regional Office in Seattle between 830 am and 400 pm Monday through Friday (see address below)
United States Environmental Protection Agency Region 10 1200 Sixth Avenue OW-130 Seattle Washington 98101 (206) 553-0523 or 1-800-424-4372 (within Alaska Idaho Oregon and Washington)
The fact sheet and draft permit are also available at
EPA Idaho Operations Office 1435 North Orchard Street Boise Idaho 83706 (208) 378-5746
Idaho Division of Environmental Quality Idaho Falls Regional Office 900 N Skyline Idaho Falls Idaho 83402 (208) 528-2650
2
Challis Public Library Sixth and Main Challis Idaho 83226
The draft permit and fact sheet can also be found by visiting the Region 10 website at wwwepagovr10earthwaterhtm
For technical questions regarding the permit or fact sheet contact Patty McGrath at the phone numbers or email address at the top of this fact sheet Those with impaired hearing or speech may contact a TDD operator at 1-800-833-6384 (ask to be connected to Patty McGrath at the above phone numbers) Additional services can be made available to person with disabilities by contacting Patty McGrath
3
TABLE OF CONTENTS
LIST OF ACRONYMS 5
I APPLICANT 6
II FACILITY ACTIVITY 6
III FACILITY BACKGROUND 7 A Permit History 7 B Compliance History 8
IV RECEIVING WATERS 8
V EFFLUENT LIMITATIONS 9
VI MONITORING REQUIREMENTS 13 A Effluent Monitoring 13 B Whole Effluent Toxicity Testing 15 C Storm Water Monitoring 15 D Receiving Water Monitoring 16 E Representative Sampling 18
VII OTHER PERMIT CONDITIONS 18 A Quality Assurance Plan 18 B Best Management Practices Plan 19 C Additional Permit Provisions 19
VIII OTHER LEGAL REQUIREMENTS 19 A Endangered Species Act 19 B State Certification 20 C Antidegradation 21 D Permit Expiration 21
APPENDIX A - FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
APPENDIX D - EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
APPENDIX E - ENDANGERED SPECIES ACT CONSULTATION
APPENDIX F - REFERENCES
4
LIST OF ACRONYMS
AML Average Monthly Limit
BAT Best Available Technology Economically Achievable BCT Best Conventional Pollutant Control Technology BMP Best Management Practices BPT Best Practicable Control Technology
CFR Code of Federal Regulations cfs cubic feet per second CV coefficient of variation CWA Clean Water Act
DMR Discharge Monitoring Report
EPA Environmental Protection Agency
IDEQ Idaho Division of Environmental Quality
LA left abutment wastewater
MDL maximum daily limit mgd million gallons per day MZ mixing zone
NPDES National Pollutant Discharge Elimination System NTR National Toxics Rule
PBS pumpback system wastewater PIT pit wastewater
RP Reasonable Potential RPM Reasonable Potential Multiplier
TCM Thompson Creek Mine TCMC Thompson Creek Mining Company tpd tons per day TSD Technical Support Document (EPA 1991) TSS Total Suspended Solids TU Toxic Unit (TUa = acute toxic unit TUc = chronic toxic unit)
USFS Unites States Forest Service
WET Whole Effluent Toxicity WLA Wasteload Allocation
5
I APPLICANT
Thompson Creek Mining Company NPDES Permit No ID-002540-2
Mailing Address
Facility Location
PO Box 62 Clayton Idaho 83227 See Figure A-1 in Appendix A
Facility Contact Bert Doughty Supervisor Environmental Affairs (208) 838-2200
II FACILITY ACTIVITY
The Thompson Creek Mine (TCM) is a molybdenum mine and mill located in Custer County Idaho approximately 30 miles southwest of Challis (see Figure A-1) The mine and mill are owned and operated by the Thompson Creek Mining Company (TCMC) The facility has been in operation since 1983 with periods of temporary closure in 1991 and from December 1992 to April 1994 At the current processing rate of 28000 to 32000 tpd the life of the TCM is estimated at 15 years
The mine facilities encompass approximately 2400 acres on both private lands and public lands The federal land area is managed by the US Forest Service (Salmon-Challis National Forest) and the US Bureau of Land Management (Challis Resource Area) The mine facilities are located in the Bruno Creek Buckskin Creek and Pat Hughes Creek drainages These creeks are tributaries to Thompson and Squaw creeks which flow into the Salmon River approximately 5 miles from the mine site (see Figure A-1)
Molybdenum ore is mined via open pit methods At the mill the ore is processed by flotation to produce a molybdenum concentrate The molybdenum concentrate is transported off-site for refining Tailings (the residuals from flotation) are piped in a slurry from the mill to the tailings impoundment The tailings impoundment is constructed in the upper Bruno Creek watershed and covers approximately 280 acres The impoundment currently contains approximately 90 million tons of tailings Waste rock (rock that is removed from the mine in order to gain access to the ore) is hauled from the mine for disposal in either the Pat Hughes or Buckskin waste rock dumps To-date approximately 350 million tons of waste rock have been disposed in the Buckskin Creek dump and 50 million tons in the Pat Hughes dump More detailed information on the TCM operations can be found in the Supplemental Plan of Operations (TCMC 1998)
The facility currently discharges wastewater from the Buckskin and Pat Hughes waste rock dumps through two outfalls (001 and 002) and storm water through Outfall 003 The proposed permit will allow discharge through two new outfalls (004 and 005) from the tailings impoundment in the event of excess precipitation or mine closure In addition wastewater from Outfalls 001 and 002 may be discharged instead out of Outfall 005 The parameters of concern
6
in the discharges include pH total suspended solids (TSS) and metals The following table summarizes each outfall A more detailed description of each outfall is proved in Appendix B A map of the outfall locations is provided in Appendix A (Figure A-2)
Table 1 Proposed NPDES Outfalls
Outfall Receiving Water Description of Discharge1 Flow Rate2
001 Thompson Creek seepage and runoff from the Buckskin waste rock dump
discharge generally occurs in April-July only calculated avg discharge = 12 cfs measured max discharge = 84 cfs
002 Thompson Creek seepage and runoff from the Pat Hughes waste rock dump
discharge continuous peaks in May - July calculated avg discharge = 07 cfs measured max discharge = 12 cfs
003 Squaw Creek storm water mine road runoff Bruno Creek diversion
discharge continuous peaks in May - July calculated avg discharge = 11 cfs measured max discharge = 97 cfs
004 Squaw Creek tailings impoundment seepage predicted max discharge = 13 cfs
005 Salmon River tailings impoundment seepage and open pit mine water3
predicted max discharge = 27 cfs
Footnotes 1 - See also Appendix B 2 - Flows are based on the last five years of monitoring conducted by TCMC 3 - TCMC may discharge effluent from outfalls 001 and 002 out of Outfall 005
III FACILITY BACKGROUND
A Permit History
EPA first issued a National Pollutant Discharge Elimination System (NPDES) permit for the TCM on June 10 1981 The current permit was reissued by EPA on August 1 1988 The current permit expired on August 2 1993 A timely application for renewal of the permit and for establishment of Outfall 004 was submitted to EPA on September 17 1992 A revised application for establishment of Outfall 005 was submitted on September 7 1993 A second revised application for Outfalls 001 and 002 (applying to discharge from either the original outfall locations or the Outfall 005 location) was submitted to EPA on February 22 2000 Additional information related to this permit reissuance was submitted by TCMC to EPA on September 1 1999 September 21 1999 and February 22 2000 Because the Permittee submitted a timely application for renewal the 1988 permit has been administratively extended and remains fully effective and enforceable until reissuance
7
On July 14 1994 a draft NPDES Permit for the TCM was issued for public notice The effluent limits for metals in the July 1994 draft permit were based on State of Idaho water quality criteria that were expressed as total recoverable While EPA was finalizing the permit the State of Idaho adopted new water quality criteria that express some metals as dissolved In addition a new criteria for arsenic was promulgated To accommodate these changes and the new information submitted by TCMC this new draft permit has been prepared and is being reissued for public comment
B Compliance History
TCMC submits monthly discharge monitoring reports (DMRs) to EPA summarizing the results of effluent monitoring required by the permit The following effluent limit violations were noted based on review of the past five yearsrsquo DMRs
Outfall 001 In June and July 1995 pH was reported at 91 (outside the pH limit of 6 - 9)
Outfall 002 Violations of the maximum daily effluent limits were reported in March 1999 (TSS only) May 1999 (TSS and zinc) and August 1999 (cadmium and zinc) TCMC attributed the March violation to heavy snow pack and the subsequent violations to a break in the pit diversion line located beneath the waste rock dump TCMC stopped discharging while investigating and fixing the break The diversion line has since been fixed and discharges are within the effluent limits
IV RECEIVING WATERS
As discussed in Section II the TCM outfalls discharge to Squaw Creek Thompson Creek and the Salmon River The Idaho Water Quality Standards and Wastewater Treatment Requirements designate beneficial uses for waters of the State These three waters are classified by the State of Idaho for protection of the following uses (1) agricultural water supply (2) cold water biota (3) salmonid spawning and (4) secondary contact recreation In addition the Salmon River is protected for domestic water supply and primary contact recreation and is classified as a Special Resource Water
The State water quality standards specify water quality criteria that is deemed necessary to support the use classifications These criteria may by numerical or narrative The water quality criteria applicable to the proposed permit are provided in Appendix C (Section IIIA) These criteria provide the basis for most of the effluent limits in the draft permit
Portions of Thompson Creek and the Salmon River are listed on Idahorsquos 303(d) list (a list of impaired waters compiled under Section 303(d) of the Clean Water Act) The 303(d) list identifies water bodies that do not meet or are not expected to meet water quality standards
Specifically these waters were listed as not meeting standards for
8
Thompson Creek (about three miles downstream from Outfall 002 to the confluence with the Salmon River) - sediment and metals
Salmon River (including the discharge location) - sediment and temperature
Section 303(d) of the Clean Water Act (CWA) requires States to develop a Total Maximum Daily Load (TMDL) management plan for water bodies on the 303(d) list A TMDL allocates loading capacities to point and nonpoint sources to the water body Permit limits for point sources must be consistent with applicable TMDL allocations A TMDL for Thompson Creek and this part of the Salmon River is scheduled to be completed in 2001 The General Provisions section of the draft permit contains a provision to allow EPA to reopen the permit (eg to incorporate any applicable effluent limitations and conditions which may result from final TMDLs on these receiving waters)
V EFFLUENT LIMITATIONS
EPA followed the Clean Water Act (CWA) state and federal regulations and EPArsquos 1991 Technical Support Document for Water Quality-Based Toxics Control (TSD) to develop the effluent limits in the draft permit In general the CWA requires that the effluent limit for a particular pollutant be the more stringent of either the technology-based limit or water quality-based limit Appendix C provides discussion on the legal basis for the development of technology-based and water quality-based effluent limits
EPA sets technology-based limits based on the effluent quality that is achievable using readily available technology The Agency evaluates the technology-based limits to determine whether they are adequate to ensure that water quality standards are met in the receiving water If the limits are not adequate EPA must develop additional water quality-based limits Water quality-based limits are designed to prevent exceedances of the Idaho water quality standards in the receiving waters
The proposed permit includes technology-based limits for total suspended solids (TSS) water quality-based and technology-based limits for pH and water quality-based limits for most metals Tables 2 and 3 compare the existing effluent limits for outfalls 001 and 002 with the proposed effluent limits in the draft permit Tables 4 and 5 include the proposed effluent limits for the new discharges from outfalls 004 and 005 Appendix C describes in detail how the effluent limits were developed
Two sets of limits (tiered limits) were developed for outfalls 001 002 and 004 to allow for seasonal variability of the flows in the receiving waters Except for pH and TSS the proposed effluent limits are expressed in terms of both mass (poundsday) and concentration (ugl) for outfalls 004 and 005 Establishment of mass-based limits ensures that total loadings to the receiving waters are controlled Mass limits were not calculated for outfalls 001 and 002 since the effluent flow from these outfalls is dependent upon precipitation and varies with the
9
receiving water flow Concentration-based limits for these outfalls were calculated based on the ratio of effluent flow to receiving water flow (the dilution ratio) for each flow tier Therefore mass loadings for these outfalls will be controlled by limiting the dilution ratio consistent with the dilution ratio used to develop the concentration-based effluent limits (see also Section IV of Appendix C)
Effluent limits were not developed for Outfall 003 Rather ldquobest management practicesrdquo (BMPs) and monitoring are the permit conditions used to address storm water (see Sections VIC and VIIB of this fact sheet)
Table 2 Effluent Limitations for Outfall 001
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1 none -shy -shy 0011 0011 0092 0092
arsenic ugl 490 -shy -shy -shy ndash ndash
cadmium ugl 532 ndash 35 24 68 47
copper ugl 2452 -shy 270 180 31 21
lead ugl 5892 -shy 94 64 19 13
mercury ugl 022 -shy 046 032 0073 0050
selenium ugl -shy -shy 1505 1105 425 305
zinc ugl 1652 -shy 1500 750 210 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals are to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
10
Table 3 Effluent Limitations for Outfall 002
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1
none -shy -shy 0085 0085 018 018
arsenic ugl 490 -shy -shy -shy -shy -shy
cadmium ugl 532 ndash 11 78 52 35
copper ugl 2452 -shy 53 36 22 15
lead ugl 5892 -shy 31 21 12 83
mercury ugl 022 -shy 0077 0053 0047 0032
selenium ugl -shy -shy 235 165 175 115
zinc ugl 1652 -shy 290 200 220 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
11
Table 4 Effluent Limitations for Outfall 004
Parameter units Proposed Effluent Limitations1
at Squaw Creek flow lt 50 cfs2 at Squaw Creek flow $ 50 cfs2
Maximum Daily Monthly Average Maximum Daily Monthly Average
cadmium ugl 12 58 26 13
lbday 0084 0041 018 0091
chromium ugl 40 20 -shy -shy
lbday 028 014 -shy -shy
copper ugl 48 24 120 58
lbday 034 017 084 041
lead ugl 37 18 21 10
lbday 026 013 015 0070
mercury ugl 0037 0018 021 010
lbday 000026 000013 00015 000070
silver ugl -shy -shy 22 11
lbday -shy -shy 015 0077
zinc ugl 290 140 860 430
lbday 20 098 60 30
TSS mgl 30 20 30 20
pH su within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be total 2 - The flow tiers are representative of flow upstream of the outfall
12
Table 5 Effluent Limitations for Outfall 005
Parameter units Proposed Effluent Limitationss
Maximum Daily Monthly Average
cadmium ugl 12 62
lbday 017 0090
copper ugl 120 59
lbday 17 086
lead ugl 21 10
lbday 030 015
mercury ugl 061 030
lbday 00089 00044
silver ugl 12 60
lbday 017 0087
zinc ugl 1000 500
lbday 15 73
TSS mgl 30 20
pH su within the range of 65 - 90
Footnote 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total
VI MONITORING REQUIREMENTS
Section 308 of the Clean Water Act and federal regulation 40 CFR 12244(i) require that monitoring be included in permits to determine compliance with effluent limitations Monitoring may also be required to gather data for future effluent limitations or to monitor effluent impacts on receiving water quality TCMC is responsible for conducting the monitoring and reporting the results to EPA on monthly DMRs and in annual reports This section describes the monitoring requirements in the draft permit
A Effluent Monitoring
The effluent monitoring requirements in the draft permit are summarized in Table 6 The monitoring frequency for outfalls 001 and 002 is the same as included in the current permit (monthly for most parameters) The monitoring frequency for most of the outfall 004 and 005
13
parameters is weekly More frequent monitoring and composite sampling was determined to be necessary for these outfalls due to the composition of the outfalls (process water) the more continuous nature of the discharges and the Special Resource status of the Salmon River (Outfall 005) Flow monitoring of the receiving waters is required for outfalls 001 002 and 004 to determine which set of tiered effluent limits apply and to calculate dilution ratios (outfalls 001 and 002 only) Monitoring of Outfall 003 is discussed in Section VIC below
Some of the water quality-based effluent limits in the draft permit are close to the capability of current analytical technology to detect andor quantify (close to method detection limits) To address this concern the draft permit contains a provision requiring TCMC to use analytical methods that can achieve a method detection limit less than the effluent limitation Method detection limits are the minimum levels that can be accurately detected by current analytical technology
Table 6 Effluent Monitoring Requirements
Parameter Outfalls 001 and 002 Outfalls 004 and 005
frequency sample type frequency sample type
dilution ratio daily calculation -shy -shy
outfall flow cfs continuous recording continuous recording
metals with effluent limits1 ugl monthly grab weekly 24-hour composite
molybdenum ugl quarterly grab quarterly 24-hour composite
selenium2 ugl monthly grab quarterly 24-hour composite
TSS mgl weekly grab weekly 24-hour composite
pH standard units (su) weekly grab daily grab
hardness as CaCO3 mgl monthly grab weekly 24-hour composite
temperature oC weekly grab weekly grab
Acute WET3 TUa annually grab annually 24-hour composite
Chronic WET3 TUc annually grab quarterly 24-hour composite
Thompson Creek Flow4 cfs daily recording daily recording
Squaw Creek Flow5 cfs daily recording daily recording
Footnotes 1 - metals to be measured include cadmium chromium (outfall 004 only) copper lead mercury selenium (outfalls 001 and 002 only) silver (outfalls 004 and 005 only) and zinc 2 - selenium monitoring required for outfalls 001 and 002 (see footnote 1) and 005 3 - See Section VIB below for specific information regarding the whole effluent toxicity (WET) monitoring 4 - Thompson Creek flow monitoring is required upstream of each outfalls 001 and 002 5 - Squaw Creek flow monitoring is required upstream of Outfall 004
14
B Whole Effluent Toxicity Testing
Whole effluent toxicity (WET) is defined as the aggregate toxic effect of an effluent measured directly by an aquatic toxicity test WET tests are standardized laboratory tests that measure the total toxic effect of an effluent by exposing organisms to the effluent and noting the effects There are two different durations of toxicity tests acute and chronic Acute toxicity tests measure the test organisms survival over a 96-hour test exposure period Chronic toxicity tests measure reductions in survival growth and reproduction over a 7-day exposure
TCMC has conducted limited WET testing on their effluents In 1993 one set of WET tests were performed on effluent from outfalls 001 and 002 and some of the sources of wastewater to outfalls 004 and 005 (LA and PBS wastewaters) Results indicated no acute toxicity Chronic toxicity was indicated for Outfall 001 and the LA and PBS wastewaters at 100 effluent however the tests were not performed at dilutions representing the mixing zones In 1999 TCMC conducted an additional set of WET tests on outfalls 001 and 002 These tests indicated no acute toxicity Chronic toxicity was indicated for one species tested on Outfall 002
Federal regulations at 40 CFR 12244(d)(1) require that permits contain limits on WET when a discharge has reasonable potential to cause or contribute to an exceedence of a water quality standard In Idaho the relevant water quality standard states that surface waters of the State shall be free from toxic substances in concentrations that impair designated beneficial uses (see Appendix C Table C-2) The TSD provides guidance on implementing WET testing in NPDES permits The preliminary CWA Section 401 Certification provided by IDEQ included specific WET testing requirements for this permit (see also Section VIIIB)
Because the limited amount of existing WET testing on the TCM effluents is not adequate to determine the need for WET effluent limits WET testing has been incorporated into the draft permit The draft permit requires TCMC to conduct acute WET testing annually on effluent from each outfall Chronic WET testing must be conducted annually for outfalls 001 and 002 and quarterly for outfalls 004 and 005 TCMC is required to perform the acute tests using the salmonid species Oncorhynchus mykiss (rainbow trout) and the chronic tests using both Pimephales promelas (fathead minnow) and Ceriodaphnia dubia (water fleas) Different species are used for testing to represent different aquatic phyla (fish and invertebrates) and because different species have different sensitivities The tests will be conducted at a range of dilutions that mimic the effluent-receiving water mixing conditions Results of these tests will be used to ensure that toxics in the effluent are controlled and to determine the need for future WET limits In addition the permit establishes toxicity trigger levels for each outfall (see Appendix C Section IVB ) that if exceeded trigger additional WET testing and potentially investigations to reduce toxicity
C Storm Water Monitoring
The current permit requires TCMC to monitor the receiving water upstream and downstream of the Outfall 003 sediment ponds for turbidity The monitoring is specified as weekly during
15
February through June and monthly for the other months of the year The draft permit continues this turbidity monitoring In addition the draft permit requires daily monitoring of effluent flow and monthly monitoring of Outfall 003 for metals (cadmium copper lead mercury and zinc) hardness TSS pH and temperature to ensure that water quality standards are maintained
The storm water discharge should not adversely affect water quality This assumes appropriate design and implementation of best management practices (BMPs) in lieu of numerical effluent limits The monitoring required in the draft permit along with periodic inspections are required to evaluate the effectiveness of BMPs and to provide sufficient information to determine if these discharges either cause or contribute to water quality standards exceedences Section VIIB below discusses the BMP requirements
D Receiving Water Monitoring
The current permit requires TCMC to provide for water quality monitoring in accordance with the program agreed upon by the Interagency Task Force (members of which include the USFS BLM IDEQ EPA and TCMC) TCMCrsquos current environmental monitoring program is described in the Consolidated Environmental Monitoring Program (TCMC 1999a) This program includes monitoring of the surface water sediments and aquatic biology in the receiving waters
The draft permit requires TCMC to continue this monitoring as it relates to the permitted discharges by specifying monitoring at selected locations within and around the discharge areas The water quality monitoring requirements in the draft permit are for the most part consistent with TCMCrsquos Consolidated Monitoring Program However some additional monitoring has been added since two new outfalls are proposed (004 and 005) one of the new outfalls (005) discharges to a Special Resource Water and to verify that bioaccumulation is not of concern The following summarizes the monitoring requirements in the draft permit
Surface Water Quality Monitoring Surface water quality monitoring of the receiving waters is required four times per year upstream and downstream of each outfall for the parameters listed in Table 7 When there is a discharge from outfalls 004 or 005 the permit requires that the monitoring frequency for metals in the Salmon River be increased to monthly This was a requirement of IDEQrsquos preliminary CWA Section 401 Certification for discharge into a Special Resource Water (see also Section VIIIB) IDEQ also required that for each sampling event metals concentrations in the receiving water be compared to aquatic life chronic water quality criteria If the concentrations exceed the criteria then future sampling for that parameter will be expanded to determine 4-day average concentrations (since chronic criteria are expressed as 4shyday average concentrations)
The receiving water quality monitoring data is used to evaluate the water quality impacts of the NPDES discharges The data will also be used during the next permitting cycle to determine the need for incorporating and retaining water quality-based effluent limits into the permit In order to perform these evaluations it is necessary that the ambient monitoring use analytical methods
16
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 3: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/3.jpg)
Challis Public Library Sixth and Main Challis Idaho 83226
The draft permit and fact sheet can also be found by visiting the Region 10 website at wwwepagovr10earthwaterhtm
For technical questions regarding the permit or fact sheet contact Patty McGrath at the phone numbers or email address at the top of this fact sheet Those with impaired hearing or speech may contact a TDD operator at 1-800-833-6384 (ask to be connected to Patty McGrath at the above phone numbers) Additional services can be made available to person with disabilities by contacting Patty McGrath
3
TABLE OF CONTENTS
LIST OF ACRONYMS 5
I APPLICANT 6
II FACILITY ACTIVITY 6
III FACILITY BACKGROUND 7 A Permit History 7 B Compliance History 8
IV RECEIVING WATERS 8
V EFFLUENT LIMITATIONS 9
VI MONITORING REQUIREMENTS 13 A Effluent Monitoring 13 B Whole Effluent Toxicity Testing 15 C Storm Water Monitoring 15 D Receiving Water Monitoring 16 E Representative Sampling 18
VII OTHER PERMIT CONDITIONS 18 A Quality Assurance Plan 18 B Best Management Practices Plan 19 C Additional Permit Provisions 19
VIII OTHER LEGAL REQUIREMENTS 19 A Endangered Species Act 19 B State Certification 20 C Antidegradation 21 D Permit Expiration 21
APPENDIX A - FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
APPENDIX D - EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
APPENDIX E - ENDANGERED SPECIES ACT CONSULTATION
APPENDIX F - REFERENCES
4
LIST OF ACRONYMS
AML Average Monthly Limit
BAT Best Available Technology Economically Achievable BCT Best Conventional Pollutant Control Technology BMP Best Management Practices BPT Best Practicable Control Technology
CFR Code of Federal Regulations cfs cubic feet per second CV coefficient of variation CWA Clean Water Act
DMR Discharge Monitoring Report
EPA Environmental Protection Agency
IDEQ Idaho Division of Environmental Quality
LA left abutment wastewater
MDL maximum daily limit mgd million gallons per day MZ mixing zone
NPDES National Pollutant Discharge Elimination System NTR National Toxics Rule
PBS pumpback system wastewater PIT pit wastewater
RP Reasonable Potential RPM Reasonable Potential Multiplier
TCM Thompson Creek Mine TCMC Thompson Creek Mining Company tpd tons per day TSD Technical Support Document (EPA 1991) TSS Total Suspended Solids TU Toxic Unit (TUa = acute toxic unit TUc = chronic toxic unit)
USFS Unites States Forest Service
WET Whole Effluent Toxicity WLA Wasteload Allocation
5
I APPLICANT
Thompson Creek Mining Company NPDES Permit No ID-002540-2
Mailing Address
Facility Location
PO Box 62 Clayton Idaho 83227 See Figure A-1 in Appendix A
Facility Contact Bert Doughty Supervisor Environmental Affairs (208) 838-2200
II FACILITY ACTIVITY
The Thompson Creek Mine (TCM) is a molybdenum mine and mill located in Custer County Idaho approximately 30 miles southwest of Challis (see Figure A-1) The mine and mill are owned and operated by the Thompson Creek Mining Company (TCMC) The facility has been in operation since 1983 with periods of temporary closure in 1991 and from December 1992 to April 1994 At the current processing rate of 28000 to 32000 tpd the life of the TCM is estimated at 15 years
The mine facilities encompass approximately 2400 acres on both private lands and public lands The federal land area is managed by the US Forest Service (Salmon-Challis National Forest) and the US Bureau of Land Management (Challis Resource Area) The mine facilities are located in the Bruno Creek Buckskin Creek and Pat Hughes Creek drainages These creeks are tributaries to Thompson and Squaw creeks which flow into the Salmon River approximately 5 miles from the mine site (see Figure A-1)
Molybdenum ore is mined via open pit methods At the mill the ore is processed by flotation to produce a molybdenum concentrate The molybdenum concentrate is transported off-site for refining Tailings (the residuals from flotation) are piped in a slurry from the mill to the tailings impoundment The tailings impoundment is constructed in the upper Bruno Creek watershed and covers approximately 280 acres The impoundment currently contains approximately 90 million tons of tailings Waste rock (rock that is removed from the mine in order to gain access to the ore) is hauled from the mine for disposal in either the Pat Hughes or Buckskin waste rock dumps To-date approximately 350 million tons of waste rock have been disposed in the Buckskin Creek dump and 50 million tons in the Pat Hughes dump More detailed information on the TCM operations can be found in the Supplemental Plan of Operations (TCMC 1998)
The facility currently discharges wastewater from the Buckskin and Pat Hughes waste rock dumps through two outfalls (001 and 002) and storm water through Outfall 003 The proposed permit will allow discharge through two new outfalls (004 and 005) from the tailings impoundment in the event of excess precipitation or mine closure In addition wastewater from Outfalls 001 and 002 may be discharged instead out of Outfall 005 The parameters of concern
6
in the discharges include pH total suspended solids (TSS) and metals The following table summarizes each outfall A more detailed description of each outfall is proved in Appendix B A map of the outfall locations is provided in Appendix A (Figure A-2)
Table 1 Proposed NPDES Outfalls
Outfall Receiving Water Description of Discharge1 Flow Rate2
001 Thompson Creek seepage and runoff from the Buckskin waste rock dump
discharge generally occurs in April-July only calculated avg discharge = 12 cfs measured max discharge = 84 cfs
002 Thompson Creek seepage and runoff from the Pat Hughes waste rock dump
discharge continuous peaks in May - July calculated avg discharge = 07 cfs measured max discharge = 12 cfs
003 Squaw Creek storm water mine road runoff Bruno Creek diversion
discharge continuous peaks in May - July calculated avg discharge = 11 cfs measured max discharge = 97 cfs
004 Squaw Creek tailings impoundment seepage predicted max discharge = 13 cfs
005 Salmon River tailings impoundment seepage and open pit mine water3
predicted max discharge = 27 cfs
Footnotes 1 - See also Appendix B 2 - Flows are based on the last five years of monitoring conducted by TCMC 3 - TCMC may discharge effluent from outfalls 001 and 002 out of Outfall 005
III FACILITY BACKGROUND
A Permit History
EPA first issued a National Pollutant Discharge Elimination System (NPDES) permit for the TCM on June 10 1981 The current permit was reissued by EPA on August 1 1988 The current permit expired on August 2 1993 A timely application for renewal of the permit and for establishment of Outfall 004 was submitted to EPA on September 17 1992 A revised application for establishment of Outfall 005 was submitted on September 7 1993 A second revised application for Outfalls 001 and 002 (applying to discharge from either the original outfall locations or the Outfall 005 location) was submitted to EPA on February 22 2000 Additional information related to this permit reissuance was submitted by TCMC to EPA on September 1 1999 September 21 1999 and February 22 2000 Because the Permittee submitted a timely application for renewal the 1988 permit has been administratively extended and remains fully effective and enforceable until reissuance
7
On July 14 1994 a draft NPDES Permit for the TCM was issued for public notice The effluent limits for metals in the July 1994 draft permit were based on State of Idaho water quality criteria that were expressed as total recoverable While EPA was finalizing the permit the State of Idaho adopted new water quality criteria that express some metals as dissolved In addition a new criteria for arsenic was promulgated To accommodate these changes and the new information submitted by TCMC this new draft permit has been prepared and is being reissued for public comment
B Compliance History
TCMC submits monthly discharge monitoring reports (DMRs) to EPA summarizing the results of effluent monitoring required by the permit The following effluent limit violations were noted based on review of the past five yearsrsquo DMRs
Outfall 001 In June and July 1995 pH was reported at 91 (outside the pH limit of 6 - 9)
Outfall 002 Violations of the maximum daily effluent limits were reported in March 1999 (TSS only) May 1999 (TSS and zinc) and August 1999 (cadmium and zinc) TCMC attributed the March violation to heavy snow pack and the subsequent violations to a break in the pit diversion line located beneath the waste rock dump TCMC stopped discharging while investigating and fixing the break The diversion line has since been fixed and discharges are within the effluent limits
IV RECEIVING WATERS
As discussed in Section II the TCM outfalls discharge to Squaw Creek Thompson Creek and the Salmon River The Idaho Water Quality Standards and Wastewater Treatment Requirements designate beneficial uses for waters of the State These three waters are classified by the State of Idaho for protection of the following uses (1) agricultural water supply (2) cold water biota (3) salmonid spawning and (4) secondary contact recreation In addition the Salmon River is protected for domestic water supply and primary contact recreation and is classified as a Special Resource Water
The State water quality standards specify water quality criteria that is deemed necessary to support the use classifications These criteria may by numerical or narrative The water quality criteria applicable to the proposed permit are provided in Appendix C (Section IIIA) These criteria provide the basis for most of the effluent limits in the draft permit
Portions of Thompson Creek and the Salmon River are listed on Idahorsquos 303(d) list (a list of impaired waters compiled under Section 303(d) of the Clean Water Act) The 303(d) list identifies water bodies that do not meet or are not expected to meet water quality standards
Specifically these waters were listed as not meeting standards for
8
Thompson Creek (about three miles downstream from Outfall 002 to the confluence with the Salmon River) - sediment and metals
Salmon River (including the discharge location) - sediment and temperature
Section 303(d) of the Clean Water Act (CWA) requires States to develop a Total Maximum Daily Load (TMDL) management plan for water bodies on the 303(d) list A TMDL allocates loading capacities to point and nonpoint sources to the water body Permit limits for point sources must be consistent with applicable TMDL allocations A TMDL for Thompson Creek and this part of the Salmon River is scheduled to be completed in 2001 The General Provisions section of the draft permit contains a provision to allow EPA to reopen the permit (eg to incorporate any applicable effluent limitations and conditions which may result from final TMDLs on these receiving waters)
V EFFLUENT LIMITATIONS
EPA followed the Clean Water Act (CWA) state and federal regulations and EPArsquos 1991 Technical Support Document for Water Quality-Based Toxics Control (TSD) to develop the effluent limits in the draft permit In general the CWA requires that the effluent limit for a particular pollutant be the more stringent of either the technology-based limit or water quality-based limit Appendix C provides discussion on the legal basis for the development of technology-based and water quality-based effluent limits
EPA sets technology-based limits based on the effluent quality that is achievable using readily available technology The Agency evaluates the technology-based limits to determine whether they are adequate to ensure that water quality standards are met in the receiving water If the limits are not adequate EPA must develop additional water quality-based limits Water quality-based limits are designed to prevent exceedances of the Idaho water quality standards in the receiving waters
The proposed permit includes technology-based limits for total suspended solids (TSS) water quality-based and technology-based limits for pH and water quality-based limits for most metals Tables 2 and 3 compare the existing effluent limits for outfalls 001 and 002 with the proposed effluent limits in the draft permit Tables 4 and 5 include the proposed effluent limits for the new discharges from outfalls 004 and 005 Appendix C describes in detail how the effluent limits were developed
Two sets of limits (tiered limits) were developed for outfalls 001 002 and 004 to allow for seasonal variability of the flows in the receiving waters Except for pH and TSS the proposed effluent limits are expressed in terms of both mass (poundsday) and concentration (ugl) for outfalls 004 and 005 Establishment of mass-based limits ensures that total loadings to the receiving waters are controlled Mass limits were not calculated for outfalls 001 and 002 since the effluent flow from these outfalls is dependent upon precipitation and varies with the
9
receiving water flow Concentration-based limits for these outfalls were calculated based on the ratio of effluent flow to receiving water flow (the dilution ratio) for each flow tier Therefore mass loadings for these outfalls will be controlled by limiting the dilution ratio consistent with the dilution ratio used to develop the concentration-based effluent limits (see also Section IV of Appendix C)
Effluent limits were not developed for Outfall 003 Rather ldquobest management practicesrdquo (BMPs) and monitoring are the permit conditions used to address storm water (see Sections VIC and VIIB of this fact sheet)
Table 2 Effluent Limitations for Outfall 001
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1 none -shy -shy 0011 0011 0092 0092
arsenic ugl 490 -shy -shy -shy ndash ndash
cadmium ugl 532 ndash 35 24 68 47
copper ugl 2452 -shy 270 180 31 21
lead ugl 5892 -shy 94 64 19 13
mercury ugl 022 -shy 046 032 0073 0050
selenium ugl -shy -shy 1505 1105 425 305
zinc ugl 1652 -shy 1500 750 210 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals are to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
10
Table 3 Effluent Limitations for Outfall 002
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1
none -shy -shy 0085 0085 018 018
arsenic ugl 490 -shy -shy -shy -shy -shy
cadmium ugl 532 ndash 11 78 52 35
copper ugl 2452 -shy 53 36 22 15
lead ugl 5892 -shy 31 21 12 83
mercury ugl 022 -shy 0077 0053 0047 0032
selenium ugl -shy -shy 235 165 175 115
zinc ugl 1652 -shy 290 200 220 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
11
Table 4 Effluent Limitations for Outfall 004
Parameter units Proposed Effluent Limitations1
at Squaw Creek flow lt 50 cfs2 at Squaw Creek flow $ 50 cfs2
Maximum Daily Monthly Average Maximum Daily Monthly Average
cadmium ugl 12 58 26 13
lbday 0084 0041 018 0091
chromium ugl 40 20 -shy -shy
lbday 028 014 -shy -shy
copper ugl 48 24 120 58
lbday 034 017 084 041
lead ugl 37 18 21 10
lbday 026 013 015 0070
mercury ugl 0037 0018 021 010
lbday 000026 000013 00015 000070
silver ugl -shy -shy 22 11
lbday -shy -shy 015 0077
zinc ugl 290 140 860 430
lbday 20 098 60 30
TSS mgl 30 20 30 20
pH su within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be total 2 - The flow tiers are representative of flow upstream of the outfall
12
Table 5 Effluent Limitations for Outfall 005
Parameter units Proposed Effluent Limitationss
Maximum Daily Monthly Average
cadmium ugl 12 62
lbday 017 0090
copper ugl 120 59
lbday 17 086
lead ugl 21 10
lbday 030 015
mercury ugl 061 030
lbday 00089 00044
silver ugl 12 60
lbday 017 0087
zinc ugl 1000 500
lbday 15 73
TSS mgl 30 20
pH su within the range of 65 - 90
Footnote 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total
VI MONITORING REQUIREMENTS
Section 308 of the Clean Water Act and federal regulation 40 CFR 12244(i) require that monitoring be included in permits to determine compliance with effluent limitations Monitoring may also be required to gather data for future effluent limitations or to monitor effluent impacts on receiving water quality TCMC is responsible for conducting the monitoring and reporting the results to EPA on monthly DMRs and in annual reports This section describes the monitoring requirements in the draft permit
A Effluent Monitoring
The effluent monitoring requirements in the draft permit are summarized in Table 6 The monitoring frequency for outfalls 001 and 002 is the same as included in the current permit (monthly for most parameters) The monitoring frequency for most of the outfall 004 and 005
13
parameters is weekly More frequent monitoring and composite sampling was determined to be necessary for these outfalls due to the composition of the outfalls (process water) the more continuous nature of the discharges and the Special Resource status of the Salmon River (Outfall 005) Flow monitoring of the receiving waters is required for outfalls 001 002 and 004 to determine which set of tiered effluent limits apply and to calculate dilution ratios (outfalls 001 and 002 only) Monitoring of Outfall 003 is discussed in Section VIC below
Some of the water quality-based effluent limits in the draft permit are close to the capability of current analytical technology to detect andor quantify (close to method detection limits) To address this concern the draft permit contains a provision requiring TCMC to use analytical methods that can achieve a method detection limit less than the effluent limitation Method detection limits are the minimum levels that can be accurately detected by current analytical technology
Table 6 Effluent Monitoring Requirements
Parameter Outfalls 001 and 002 Outfalls 004 and 005
frequency sample type frequency sample type
dilution ratio daily calculation -shy -shy
outfall flow cfs continuous recording continuous recording
metals with effluent limits1 ugl monthly grab weekly 24-hour composite
molybdenum ugl quarterly grab quarterly 24-hour composite
selenium2 ugl monthly grab quarterly 24-hour composite
TSS mgl weekly grab weekly 24-hour composite
pH standard units (su) weekly grab daily grab
hardness as CaCO3 mgl monthly grab weekly 24-hour composite
temperature oC weekly grab weekly grab
Acute WET3 TUa annually grab annually 24-hour composite
Chronic WET3 TUc annually grab quarterly 24-hour composite
Thompson Creek Flow4 cfs daily recording daily recording
Squaw Creek Flow5 cfs daily recording daily recording
Footnotes 1 - metals to be measured include cadmium chromium (outfall 004 only) copper lead mercury selenium (outfalls 001 and 002 only) silver (outfalls 004 and 005 only) and zinc 2 - selenium monitoring required for outfalls 001 and 002 (see footnote 1) and 005 3 - See Section VIB below for specific information regarding the whole effluent toxicity (WET) monitoring 4 - Thompson Creek flow monitoring is required upstream of each outfalls 001 and 002 5 - Squaw Creek flow monitoring is required upstream of Outfall 004
14
B Whole Effluent Toxicity Testing
Whole effluent toxicity (WET) is defined as the aggregate toxic effect of an effluent measured directly by an aquatic toxicity test WET tests are standardized laboratory tests that measure the total toxic effect of an effluent by exposing organisms to the effluent and noting the effects There are two different durations of toxicity tests acute and chronic Acute toxicity tests measure the test organisms survival over a 96-hour test exposure period Chronic toxicity tests measure reductions in survival growth and reproduction over a 7-day exposure
TCMC has conducted limited WET testing on their effluents In 1993 one set of WET tests were performed on effluent from outfalls 001 and 002 and some of the sources of wastewater to outfalls 004 and 005 (LA and PBS wastewaters) Results indicated no acute toxicity Chronic toxicity was indicated for Outfall 001 and the LA and PBS wastewaters at 100 effluent however the tests were not performed at dilutions representing the mixing zones In 1999 TCMC conducted an additional set of WET tests on outfalls 001 and 002 These tests indicated no acute toxicity Chronic toxicity was indicated for one species tested on Outfall 002
Federal regulations at 40 CFR 12244(d)(1) require that permits contain limits on WET when a discharge has reasonable potential to cause or contribute to an exceedence of a water quality standard In Idaho the relevant water quality standard states that surface waters of the State shall be free from toxic substances in concentrations that impair designated beneficial uses (see Appendix C Table C-2) The TSD provides guidance on implementing WET testing in NPDES permits The preliminary CWA Section 401 Certification provided by IDEQ included specific WET testing requirements for this permit (see also Section VIIIB)
Because the limited amount of existing WET testing on the TCM effluents is not adequate to determine the need for WET effluent limits WET testing has been incorporated into the draft permit The draft permit requires TCMC to conduct acute WET testing annually on effluent from each outfall Chronic WET testing must be conducted annually for outfalls 001 and 002 and quarterly for outfalls 004 and 005 TCMC is required to perform the acute tests using the salmonid species Oncorhynchus mykiss (rainbow trout) and the chronic tests using both Pimephales promelas (fathead minnow) and Ceriodaphnia dubia (water fleas) Different species are used for testing to represent different aquatic phyla (fish and invertebrates) and because different species have different sensitivities The tests will be conducted at a range of dilutions that mimic the effluent-receiving water mixing conditions Results of these tests will be used to ensure that toxics in the effluent are controlled and to determine the need for future WET limits In addition the permit establishes toxicity trigger levels for each outfall (see Appendix C Section IVB ) that if exceeded trigger additional WET testing and potentially investigations to reduce toxicity
C Storm Water Monitoring
The current permit requires TCMC to monitor the receiving water upstream and downstream of the Outfall 003 sediment ponds for turbidity The monitoring is specified as weekly during
15
February through June and monthly for the other months of the year The draft permit continues this turbidity monitoring In addition the draft permit requires daily monitoring of effluent flow and monthly monitoring of Outfall 003 for metals (cadmium copper lead mercury and zinc) hardness TSS pH and temperature to ensure that water quality standards are maintained
The storm water discharge should not adversely affect water quality This assumes appropriate design and implementation of best management practices (BMPs) in lieu of numerical effluent limits The monitoring required in the draft permit along with periodic inspections are required to evaluate the effectiveness of BMPs and to provide sufficient information to determine if these discharges either cause or contribute to water quality standards exceedences Section VIIB below discusses the BMP requirements
D Receiving Water Monitoring
The current permit requires TCMC to provide for water quality monitoring in accordance with the program agreed upon by the Interagency Task Force (members of which include the USFS BLM IDEQ EPA and TCMC) TCMCrsquos current environmental monitoring program is described in the Consolidated Environmental Monitoring Program (TCMC 1999a) This program includes monitoring of the surface water sediments and aquatic biology in the receiving waters
The draft permit requires TCMC to continue this monitoring as it relates to the permitted discharges by specifying monitoring at selected locations within and around the discharge areas The water quality monitoring requirements in the draft permit are for the most part consistent with TCMCrsquos Consolidated Monitoring Program However some additional monitoring has been added since two new outfalls are proposed (004 and 005) one of the new outfalls (005) discharges to a Special Resource Water and to verify that bioaccumulation is not of concern The following summarizes the monitoring requirements in the draft permit
Surface Water Quality Monitoring Surface water quality monitoring of the receiving waters is required four times per year upstream and downstream of each outfall for the parameters listed in Table 7 When there is a discharge from outfalls 004 or 005 the permit requires that the monitoring frequency for metals in the Salmon River be increased to monthly This was a requirement of IDEQrsquos preliminary CWA Section 401 Certification for discharge into a Special Resource Water (see also Section VIIIB) IDEQ also required that for each sampling event metals concentrations in the receiving water be compared to aquatic life chronic water quality criteria If the concentrations exceed the criteria then future sampling for that parameter will be expanded to determine 4-day average concentrations (since chronic criteria are expressed as 4shyday average concentrations)
The receiving water quality monitoring data is used to evaluate the water quality impacts of the NPDES discharges The data will also be used during the next permitting cycle to determine the need for incorporating and retaining water quality-based effluent limits into the permit In order to perform these evaluations it is necessary that the ambient monitoring use analytical methods
16
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 4: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/4.jpg)
TABLE OF CONTENTS
LIST OF ACRONYMS 5
I APPLICANT 6
II FACILITY ACTIVITY 6
III FACILITY BACKGROUND 7 A Permit History 7 B Compliance History 8
IV RECEIVING WATERS 8
V EFFLUENT LIMITATIONS 9
VI MONITORING REQUIREMENTS 13 A Effluent Monitoring 13 B Whole Effluent Toxicity Testing 15 C Storm Water Monitoring 15 D Receiving Water Monitoring 16 E Representative Sampling 18
VII OTHER PERMIT CONDITIONS 18 A Quality Assurance Plan 18 B Best Management Practices Plan 19 C Additional Permit Provisions 19
VIII OTHER LEGAL REQUIREMENTS 19 A Endangered Species Act 19 B State Certification 20 C Antidegradation 21 D Permit Expiration 21
APPENDIX A - FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
APPENDIX D - EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
APPENDIX E - ENDANGERED SPECIES ACT CONSULTATION
APPENDIX F - REFERENCES
4
LIST OF ACRONYMS
AML Average Monthly Limit
BAT Best Available Technology Economically Achievable BCT Best Conventional Pollutant Control Technology BMP Best Management Practices BPT Best Practicable Control Technology
CFR Code of Federal Regulations cfs cubic feet per second CV coefficient of variation CWA Clean Water Act
DMR Discharge Monitoring Report
EPA Environmental Protection Agency
IDEQ Idaho Division of Environmental Quality
LA left abutment wastewater
MDL maximum daily limit mgd million gallons per day MZ mixing zone
NPDES National Pollutant Discharge Elimination System NTR National Toxics Rule
PBS pumpback system wastewater PIT pit wastewater
RP Reasonable Potential RPM Reasonable Potential Multiplier
TCM Thompson Creek Mine TCMC Thompson Creek Mining Company tpd tons per day TSD Technical Support Document (EPA 1991) TSS Total Suspended Solids TU Toxic Unit (TUa = acute toxic unit TUc = chronic toxic unit)
USFS Unites States Forest Service
WET Whole Effluent Toxicity WLA Wasteload Allocation
5
I APPLICANT
Thompson Creek Mining Company NPDES Permit No ID-002540-2
Mailing Address
Facility Location
PO Box 62 Clayton Idaho 83227 See Figure A-1 in Appendix A
Facility Contact Bert Doughty Supervisor Environmental Affairs (208) 838-2200
II FACILITY ACTIVITY
The Thompson Creek Mine (TCM) is a molybdenum mine and mill located in Custer County Idaho approximately 30 miles southwest of Challis (see Figure A-1) The mine and mill are owned and operated by the Thompson Creek Mining Company (TCMC) The facility has been in operation since 1983 with periods of temporary closure in 1991 and from December 1992 to April 1994 At the current processing rate of 28000 to 32000 tpd the life of the TCM is estimated at 15 years
The mine facilities encompass approximately 2400 acres on both private lands and public lands The federal land area is managed by the US Forest Service (Salmon-Challis National Forest) and the US Bureau of Land Management (Challis Resource Area) The mine facilities are located in the Bruno Creek Buckskin Creek and Pat Hughes Creek drainages These creeks are tributaries to Thompson and Squaw creeks which flow into the Salmon River approximately 5 miles from the mine site (see Figure A-1)
Molybdenum ore is mined via open pit methods At the mill the ore is processed by flotation to produce a molybdenum concentrate The molybdenum concentrate is transported off-site for refining Tailings (the residuals from flotation) are piped in a slurry from the mill to the tailings impoundment The tailings impoundment is constructed in the upper Bruno Creek watershed and covers approximately 280 acres The impoundment currently contains approximately 90 million tons of tailings Waste rock (rock that is removed from the mine in order to gain access to the ore) is hauled from the mine for disposal in either the Pat Hughes or Buckskin waste rock dumps To-date approximately 350 million tons of waste rock have been disposed in the Buckskin Creek dump and 50 million tons in the Pat Hughes dump More detailed information on the TCM operations can be found in the Supplemental Plan of Operations (TCMC 1998)
The facility currently discharges wastewater from the Buckskin and Pat Hughes waste rock dumps through two outfalls (001 and 002) and storm water through Outfall 003 The proposed permit will allow discharge through two new outfalls (004 and 005) from the tailings impoundment in the event of excess precipitation or mine closure In addition wastewater from Outfalls 001 and 002 may be discharged instead out of Outfall 005 The parameters of concern
6
in the discharges include pH total suspended solids (TSS) and metals The following table summarizes each outfall A more detailed description of each outfall is proved in Appendix B A map of the outfall locations is provided in Appendix A (Figure A-2)
Table 1 Proposed NPDES Outfalls
Outfall Receiving Water Description of Discharge1 Flow Rate2
001 Thompson Creek seepage and runoff from the Buckskin waste rock dump
discharge generally occurs in April-July only calculated avg discharge = 12 cfs measured max discharge = 84 cfs
002 Thompson Creek seepage and runoff from the Pat Hughes waste rock dump
discharge continuous peaks in May - July calculated avg discharge = 07 cfs measured max discharge = 12 cfs
003 Squaw Creek storm water mine road runoff Bruno Creek diversion
discharge continuous peaks in May - July calculated avg discharge = 11 cfs measured max discharge = 97 cfs
004 Squaw Creek tailings impoundment seepage predicted max discharge = 13 cfs
005 Salmon River tailings impoundment seepage and open pit mine water3
predicted max discharge = 27 cfs
Footnotes 1 - See also Appendix B 2 - Flows are based on the last five years of monitoring conducted by TCMC 3 - TCMC may discharge effluent from outfalls 001 and 002 out of Outfall 005
III FACILITY BACKGROUND
A Permit History
EPA first issued a National Pollutant Discharge Elimination System (NPDES) permit for the TCM on June 10 1981 The current permit was reissued by EPA on August 1 1988 The current permit expired on August 2 1993 A timely application for renewal of the permit and for establishment of Outfall 004 was submitted to EPA on September 17 1992 A revised application for establishment of Outfall 005 was submitted on September 7 1993 A second revised application for Outfalls 001 and 002 (applying to discharge from either the original outfall locations or the Outfall 005 location) was submitted to EPA on February 22 2000 Additional information related to this permit reissuance was submitted by TCMC to EPA on September 1 1999 September 21 1999 and February 22 2000 Because the Permittee submitted a timely application for renewal the 1988 permit has been administratively extended and remains fully effective and enforceable until reissuance
7
On July 14 1994 a draft NPDES Permit for the TCM was issued for public notice The effluent limits for metals in the July 1994 draft permit were based on State of Idaho water quality criteria that were expressed as total recoverable While EPA was finalizing the permit the State of Idaho adopted new water quality criteria that express some metals as dissolved In addition a new criteria for arsenic was promulgated To accommodate these changes and the new information submitted by TCMC this new draft permit has been prepared and is being reissued for public comment
B Compliance History
TCMC submits monthly discharge monitoring reports (DMRs) to EPA summarizing the results of effluent monitoring required by the permit The following effluent limit violations were noted based on review of the past five yearsrsquo DMRs
Outfall 001 In June and July 1995 pH was reported at 91 (outside the pH limit of 6 - 9)
Outfall 002 Violations of the maximum daily effluent limits were reported in March 1999 (TSS only) May 1999 (TSS and zinc) and August 1999 (cadmium and zinc) TCMC attributed the March violation to heavy snow pack and the subsequent violations to a break in the pit diversion line located beneath the waste rock dump TCMC stopped discharging while investigating and fixing the break The diversion line has since been fixed and discharges are within the effluent limits
IV RECEIVING WATERS
As discussed in Section II the TCM outfalls discharge to Squaw Creek Thompson Creek and the Salmon River The Idaho Water Quality Standards and Wastewater Treatment Requirements designate beneficial uses for waters of the State These three waters are classified by the State of Idaho for protection of the following uses (1) agricultural water supply (2) cold water biota (3) salmonid spawning and (4) secondary contact recreation In addition the Salmon River is protected for domestic water supply and primary contact recreation and is classified as a Special Resource Water
The State water quality standards specify water quality criteria that is deemed necessary to support the use classifications These criteria may by numerical or narrative The water quality criteria applicable to the proposed permit are provided in Appendix C (Section IIIA) These criteria provide the basis for most of the effluent limits in the draft permit
Portions of Thompson Creek and the Salmon River are listed on Idahorsquos 303(d) list (a list of impaired waters compiled under Section 303(d) of the Clean Water Act) The 303(d) list identifies water bodies that do not meet or are not expected to meet water quality standards
Specifically these waters were listed as not meeting standards for
8
Thompson Creek (about three miles downstream from Outfall 002 to the confluence with the Salmon River) - sediment and metals
Salmon River (including the discharge location) - sediment and temperature
Section 303(d) of the Clean Water Act (CWA) requires States to develop a Total Maximum Daily Load (TMDL) management plan for water bodies on the 303(d) list A TMDL allocates loading capacities to point and nonpoint sources to the water body Permit limits for point sources must be consistent with applicable TMDL allocations A TMDL for Thompson Creek and this part of the Salmon River is scheduled to be completed in 2001 The General Provisions section of the draft permit contains a provision to allow EPA to reopen the permit (eg to incorporate any applicable effluent limitations and conditions which may result from final TMDLs on these receiving waters)
V EFFLUENT LIMITATIONS
EPA followed the Clean Water Act (CWA) state and federal regulations and EPArsquos 1991 Technical Support Document for Water Quality-Based Toxics Control (TSD) to develop the effluent limits in the draft permit In general the CWA requires that the effluent limit for a particular pollutant be the more stringent of either the technology-based limit or water quality-based limit Appendix C provides discussion on the legal basis for the development of technology-based and water quality-based effluent limits
EPA sets technology-based limits based on the effluent quality that is achievable using readily available technology The Agency evaluates the technology-based limits to determine whether they are adequate to ensure that water quality standards are met in the receiving water If the limits are not adequate EPA must develop additional water quality-based limits Water quality-based limits are designed to prevent exceedances of the Idaho water quality standards in the receiving waters
The proposed permit includes technology-based limits for total suspended solids (TSS) water quality-based and technology-based limits for pH and water quality-based limits for most metals Tables 2 and 3 compare the existing effluent limits for outfalls 001 and 002 with the proposed effluent limits in the draft permit Tables 4 and 5 include the proposed effluent limits for the new discharges from outfalls 004 and 005 Appendix C describes in detail how the effluent limits were developed
Two sets of limits (tiered limits) were developed for outfalls 001 002 and 004 to allow for seasonal variability of the flows in the receiving waters Except for pH and TSS the proposed effluent limits are expressed in terms of both mass (poundsday) and concentration (ugl) for outfalls 004 and 005 Establishment of mass-based limits ensures that total loadings to the receiving waters are controlled Mass limits were not calculated for outfalls 001 and 002 since the effluent flow from these outfalls is dependent upon precipitation and varies with the
9
receiving water flow Concentration-based limits for these outfalls were calculated based on the ratio of effluent flow to receiving water flow (the dilution ratio) for each flow tier Therefore mass loadings for these outfalls will be controlled by limiting the dilution ratio consistent with the dilution ratio used to develop the concentration-based effluent limits (see also Section IV of Appendix C)
Effluent limits were not developed for Outfall 003 Rather ldquobest management practicesrdquo (BMPs) and monitoring are the permit conditions used to address storm water (see Sections VIC and VIIB of this fact sheet)
Table 2 Effluent Limitations for Outfall 001
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1 none -shy -shy 0011 0011 0092 0092
arsenic ugl 490 -shy -shy -shy ndash ndash
cadmium ugl 532 ndash 35 24 68 47
copper ugl 2452 -shy 270 180 31 21
lead ugl 5892 -shy 94 64 19 13
mercury ugl 022 -shy 046 032 0073 0050
selenium ugl -shy -shy 1505 1105 425 305
zinc ugl 1652 -shy 1500 750 210 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals are to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
10
Table 3 Effluent Limitations for Outfall 002
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1
none -shy -shy 0085 0085 018 018
arsenic ugl 490 -shy -shy -shy -shy -shy
cadmium ugl 532 ndash 11 78 52 35
copper ugl 2452 -shy 53 36 22 15
lead ugl 5892 -shy 31 21 12 83
mercury ugl 022 -shy 0077 0053 0047 0032
selenium ugl -shy -shy 235 165 175 115
zinc ugl 1652 -shy 290 200 220 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
11
Table 4 Effluent Limitations for Outfall 004
Parameter units Proposed Effluent Limitations1
at Squaw Creek flow lt 50 cfs2 at Squaw Creek flow $ 50 cfs2
Maximum Daily Monthly Average Maximum Daily Monthly Average
cadmium ugl 12 58 26 13
lbday 0084 0041 018 0091
chromium ugl 40 20 -shy -shy
lbday 028 014 -shy -shy
copper ugl 48 24 120 58
lbday 034 017 084 041
lead ugl 37 18 21 10
lbday 026 013 015 0070
mercury ugl 0037 0018 021 010
lbday 000026 000013 00015 000070
silver ugl -shy -shy 22 11
lbday -shy -shy 015 0077
zinc ugl 290 140 860 430
lbday 20 098 60 30
TSS mgl 30 20 30 20
pH su within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be total 2 - The flow tiers are representative of flow upstream of the outfall
12
Table 5 Effluent Limitations for Outfall 005
Parameter units Proposed Effluent Limitationss
Maximum Daily Monthly Average
cadmium ugl 12 62
lbday 017 0090
copper ugl 120 59
lbday 17 086
lead ugl 21 10
lbday 030 015
mercury ugl 061 030
lbday 00089 00044
silver ugl 12 60
lbday 017 0087
zinc ugl 1000 500
lbday 15 73
TSS mgl 30 20
pH su within the range of 65 - 90
Footnote 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total
VI MONITORING REQUIREMENTS
Section 308 of the Clean Water Act and federal regulation 40 CFR 12244(i) require that monitoring be included in permits to determine compliance with effluent limitations Monitoring may also be required to gather data for future effluent limitations or to monitor effluent impacts on receiving water quality TCMC is responsible for conducting the monitoring and reporting the results to EPA on monthly DMRs and in annual reports This section describes the monitoring requirements in the draft permit
A Effluent Monitoring
The effluent monitoring requirements in the draft permit are summarized in Table 6 The monitoring frequency for outfalls 001 and 002 is the same as included in the current permit (monthly for most parameters) The monitoring frequency for most of the outfall 004 and 005
13
parameters is weekly More frequent monitoring and composite sampling was determined to be necessary for these outfalls due to the composition of the outfalls (process water) the more continuous nature of the discharges and the Special Resource status of the Salmon River (Outfall 005) Flow monitoring of the receiving waters is required for outfalls 001 002 and 004 to determine which set of tiered effluent limits apply and to calculate dilution ratios (outfalls 001 and 002 only) Monitoring of Outfall 003 is discussed in Section VIC below
Some of the water quality-based effluent limits in the draft permit are close to the capability of current analytical technology to detect andor quantify (close to method detection limits) To address this concern the draft permit contains a provision requiring TCMC to use analytical methods that can achieve a method detection limit less than the effluent limitation Method detection limits are the minimum levels that can be accurately detected by current analytical technology
Table 6 Effluent Monitoring Requirements
Parameter Outfalls 001 and 002 Outfalls 004 and 005
frequency sample type frequency sample type
dilution ratio daily calculation -shy -shy
outfall flow cfs continuous recording continuous recording
metals with effluent limits1 ugl monthly grab weekly 24-hour composite
molybdenum ugl quarterly grab quarterly 24-hour composite
selenium2 ugl monthly grab quarterly 24-hour composite
TSS mgl weekly grab weekly 24-hour composite
pH standard units (su) weekly grab daily grab
hardness as CaCO3 mgl monthly grab weekly 24-hour composite
temperature oC weekly grab weekly grab
Acute WET3 TUa annually grab annually 24-hour composite
Chronic WET3 TUc annually grab quarterly 24-hour composite
Thompson Creek Flow4 cfs daily recording daily recording
Squaw Creek Flow5 cfs daily recording daily recording
Footnotes 1 - metals to be measured include cadmium chromium (outfall 004 only) copper lead mercury selenium (outfalls 001 and 002 only) silver (outfalls 004 and 005 only) and zinc 2 - selenium monitoring required for outfalls 001 and 002 (see footnote 1) and 005 3 - See Section VIB below for specific information regarding the whole effluent toxicity (WET) monitoring 4 - Thompson Creek flow monitoring is required upstream of each outfalls 001 and 002 5 - Squaw Creek flow monitoring is required upstream of Outfall 004
14
B Whole Effluent Toxicity Testing
Whole effluent toxicity (WET) is defined as the aggregate toxic effect of an effluent measured directly by an aquatic toxicity test WET tests are standardized laboratory tests that measure the total toxic effect of an effluent by exposing organisms to the effluent and noting the effects There are two different durations of toxicity tests acute and chronic Acute toxicity tests measure the test organisms survival over a 96-hour test exposure period Chronic toxicity tests measure reductions in survival growth and reproduction over a 7-day exposure
TCMC has conducted limited WET testing on their effluents In 1993 one set of WET tests were performed on effluent from outfalls 001 and 002 and some of the sources of wastewater to outfalls 004 and 005 (LA and PBS wastewaters) Results indicated no acute toxicity Chronic toxicity was indicated for Outfall 001 and the LA and PBS wastewaters at 100 effluent however the tests were not performed at dilutions representing the mixing zones In 1999 TCMC conducted an additional set of WET tests on outfalls 001 and 002 These tests indicated no acute toxicity Chronic toxicity was indicated for one species tested on Outfall 002
Federal regulations at 40 CFR 12244(d)(1) require that permits contain limits on WET when a discharge has reasonable potential to cause or contribute to an exceedence of a water quality standard In Idaho the relevant water quality standard states that surface waters of the State shall be free from toxic substances in concentrations that impair designated beneficial uses (see Appendix C Table C-2) The TSD provides guidance on implementing WET testing in NPDES permits The preliminary CWA Section 401 Certification provided by IDEQ included specific WET testing requirements for this permit (see also Section VIIIB)
Because the limited amount of existing WET testing on the TCM effluents is not adequate to determine the need for WET effluent limits WET testing has been incorporated into the draft permit The draft permit requires TCMC to conduct acute WET testing annually on effluent from each outfall Chronic WET testing must be conducted annually for outfalls 001 and 002 and quarterly for outfalls 004 and 005 TCMC is required to perform the acute tests using the salmonid species Oncorhynchus mykiss (rainbow trout) and the chronic tests using both Pimephales promelas (fathead minnow) and Ceriodaphnia dubia (water fleas) Different species are used for testing to represent different aquatic phyla (fish and invertebrates) and because different species have different sensitivities The tests will be conducted at a range of dilutions that mimic the effluent-receiving water mixing conditions Results of these tests will be used to ensure that toxics in the effluent are controlled and to determine the need for future WET limits In addition the permit establishes toxicity trigger levels for each outfall (see Appendix C Section IVB ) that if exceeded trigger additional WET testing and potentially investigations to reduce toxicity
C Storm Water Monitoring
The current permit requires TCMC to monitor the receiving water upstream and downstream of the Outfall 003 sediment ponds for turbidity The monitoring is specified as weekly during
15
February through June and monthly for the other months of the year The draft permit continues this turbidity monitoring In addition the draft permit requires daily monitoring of effluent flow and monthly monitoring of Outfall 003 for metals (cadmium copper lead mercury and zinc) hardness TSS pH and temperature to ensure that water quality standards are maintained
The storm water discharge should not adversely affect water quality This assumes appropriate design and implementation of best management practices (BMPs) in lieu of numerical effluent limits The monitoring required in the draft permit along with periodic inspections are required to evaluate the effectiveness of BMPs and to provide sufficient information to determine if these discharges either cause or contribute to water quality standards exceedences Section VIIB below discusses the BMP requirements
D Receiving Water Monitoring
The current permit requires TCMC to provide for water quality monitoring in accordance with the program agreed upon by the Interagency Task Force (members of which include the USFS BLM IDEQ EPA and TCMC) TCMCrsquos current environmental monitoring program is described in the Consolidated Environmental Monitoring Program (TCMC 1999a) This program includes monitoring of the surface water sediments and aquatic biology in the receiving waters
The draft permit requires TCMC to continue this monitoring as it relates to the permitted discharges by specifying monitoring at selected locations within and around the discharge areas The water quality monitoring requirements in the draft permit are for the most part consistent with TCMCrsquos Consolidated Monitoring Program However some additional monitoring has been added since two new outfalls are proposed (004 and 005) one of the new outfalls (005) discharges to a Special Resource Water and to verify that bioaccumulation is not of concern The following summarizes the monitoring requirements in the draft permit
Surface Water Quality Monitoring Surface water quality monitoring of the receiving waters is required four times per year upstream and downstream of each outfall for the parameters listed in Table 7 When there is a discharge from outfalls 004 or 005 the permit requires that the monitoring frequency for metals in the Salmon River be increased to monthly This was a requirement of IDEQrsquos preliminary CWA Section 401 Certification for discharge into a Special Resource Water (see also Section VIIIB) IDEQ also required that for each sampling event metals concentrations in the receiving water be compared to aquatic life chronic water quality criteria If the concentrations exceed the criteria then future sampling for that parameter will be expanded to determine 4-day average concentrations (since chronic criteria are expressed as 4shyday average concentrations)
The receiving water quality monitoring data is used to evaluate the water quality impacts of the NPDES discharges The data will also be used during the next permitting cycle to determine the need for incorporating and retaining water quality-based effluent limits into the permit In order to perform these evaluations it is necessary that the ambient monitoring use analytical methods
16
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 5: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/5.jpg)
LIST OF ACRONYMS
AML Average Monthly Limit
BAT Best Available Technology Economically Achievable BCT Best Conventional Pollutant Control Technology BMP Best Management Practices BPT Best Practicable Control Technology
CFR Code of Federal Regulations cfs cubic feet per second CV coefficient of variation CWA Clean Water Act
DMR Discharge Monitoring Report
EPA Environmental Protection Agency
IDEQ Idaho Division of Environmental Quality
LA left abutment wastewater
MDL maximum daily limit mgd million gallons per day MZ mixing zone
NPDES National Pollutant Discharge Elimination System NTR National Toxics Rule
PBS pumpback system wastewater PIT pit wastewater
RP Reasonable Potential RPM Reasonable Potential Multiplier
TCM Thompson Creek Mine TCMC Thompson Creek Mining Company tpd tons per day TSD Technical Support Document (EPA 1991) TSS Total Suspended Solids TU Toxic Unit (TUa = acute toxic unit TUc = chronic toxic unit)
USFS Unites States Forest Service
WET Whole Effluent Toxicity WLA Wasteload Allocation
5
I APPLICANT
Thompson Creek Mining Company NPDES Permit No ID-002540-2
Mailing Address
Facility Location
PO Box 62 Clayton Idaho 83227 See Figure A-1 in Appendix A
Facility Contact Bert Doughty Supervisor Environmental Affairs (208) 838-2200
II FACILITY ACTIVITY
The Thompson Creek Mine (TCM) is a molybdenum mine and mill located in Custer County Idaho approximately 30 miles southwest of Challis (see Figure A-1) The mine and mill are owned and operated by the Thompson Creek Mining Company (TCMC) The facility has been in operation since 1983 with periods of temporary closure in 1991 and from December 1992 to April 1994 At the current processing rate of 28000 to 32000 tpd the life of the TCM is estimated at 15 years
The mine facilities encompass approximately 2400 acres on both private lands and public lands The federal land area is managed by the US Forest Service (Salmon-Challis National Forest) and the US Bureau of Land Management (Challis Resource Area) The mine facilities are located in the Bruno Creek Buckskin Creek and Pat Hughes Creek drainages These creeks are tributaries to Thompson and Squaw creeks which flow into the Salmon River approximately 5 miles from the mine site (see Figure A-1)
Molybdenum ore is mined via open pit methods At the mill the ore is processed by flotation to produce a molybdenum concentrate The molybdenum concentrate is transported off-site for refining Tailings (the residuals from flotation) are piped in a slurry from the mill to the tailings impoundment The tailings impoundment is constructed in the upper Bruno Creek watershed and covers approximately 280 acres The impoundment currently contains approximately 90 million tons of tailings Waste rock (rock that is removed from the mine in order to gain access to the ore) is hauled from the mine for disposal in either the Pat Hughes or Buckskin waste rock dumps To-date approximately 350 million tons of waste rock have been disposed in the Buckskin Creek dump and 50 million tons in the Pat Hughes dump More detailed information on the TCM operations can be found in the Supplemental Plan of Operations (TCMC 1998)
The facility currently discharges wastewater from the Buckskin and Pat Hughes waste rock dumps through two outfalls (001 and 002) and storm water through Outfall 003 The proposed permit will allow discharge through two new outfalls (004 and 005) from the tailings impoundment in the event of excess precipitation or mine closure In addition wastewater from Outfalls 001 and 002 may be discharged instead out of Outfall 005 The parameters of concern
6
in the discharges include pH total suspended solids (TSS) and metals The following table summarizes each outfall A more detailed description of each outfall is proved in Appendix B A map of the outfall locations is provided in Appendix A (Figure A-2)
Table 1 Proposed NPDES Outfalls
Outfall Receiving Water Description of Discharge1 Flow Rate2
001 Thompson Creek seepage and runoff from the Buckskin waste rock dump
discharge generally occurs in April-July only calculated avg discharge = 12 cfs measured max discharge = 84 cfs
002 Thompson Creek seepage and runoff from the Pat Hughes waste rock dump
discharge continuous peaks in May - July calculated avg discharge = 07 cfs measured max discharge = 12 cfs
003 Squaw Creek storm water mine road runoff Bruno Creek diversion
discharge continuous peaks in May - July calculated avg discharge = 11 cfs measured max discharge = 97 cfs
004 Squaw Creek tailings impoundment seepage predicted max discharge = 13 cfs
005 Salmon River tailings impoundment seepage and open pit mine water3
predicted max discharge = 27 cfs
Footnotes 1 - See also Appendix B 2 - Flows are based on the last five years of monitoring conducted by TCMC 3 - TCMC may discharge effluent from outfalls 001 and 002 out of Outfall 005
III FACILITY BACKGROUND
A Permit History
EPA first issued a National Pollutant Discharge Elimination System (NPDES) permit for the TCM on June 10 1981 The current permit was reissued by EPA on August 1 1988 The current permit expired on August 2 1993 A timely application for renewal of the permit and for establishment of Outfall 004 was submitted to EPA on September 17 1992 A revised application for establishment of Outfall 005 was submitted on September 7 1993 A second revised application for Outfalls 001 and 002 (applying to discharge from either the original outfall locations or the Outfall 005 location) was submitted to EPA on February 22 2000 Additional information related to this permit reissuance was submitted by TCMC to EPA on September 1 1999 September 21 1999 and February 22 2000 Because the Permittee submitted a timely application for renewal the 1988 permit has been administratively extended and remains fully effective and enforceable until reissuance
7
On July 14 1994 a draft NPDES Permit for the TCM was issued for public notice The effluent limits for metals in the July 1994 draft permit were based on State of Idaho water quality criteria that were expressed as total recoverable While EPA was finalizing the permit the State of Idaho adopted new water quality criteria that express some metals as dissolved In addition a new criteria for arsenic was promulgated To accommodate these changes and the new information submitted by TCMC this new draft permit has been prepared and is being reissued for public comment
B Compliance History
TCMC submits monthly discharge monitoring reports (DMRs) to EPA summarizing the results of effluent monitoring required by the permit The following effluent limit violations were noted based on review of the past five yearsrsquo DMRs
Outfall 001 In June and July 1995 pH was reported at 91 (outside the pH limit of 6 - 9)
Outfall 002 Violations of the maximum daily effluent limits were reported in March 1999 (TSS only) May 1999 (TSS and zinc) and August 1999 (cadmium and zinc) TCMC attributed the March violation to heavy snow pack and the subsequent violations to a break in the pit diversion line located beneath the waste rock dump TCMC stopped discharging while investigating and fixing the break The diversion line has since been fixed and discharges are within the effluent limits
IV RECEIVING WATERS
As discussed in Section II the TCM outfalls discharge to Squaw Creek Thompson Creek and the Salmon River The Idaho Water Quality Standards and Wastewater Treatment Requirements designate beneficial uses for waters of the State These three waters are classified by the State of Idaho for protection of the following uses (1) agricultural water supply (2) cold water biota (3) salmonid spawning and (4) secondary contact recreation In addition the Salmon River is protected for domestic water supply and primary contact recreation and is classified as a Special Resource Water
The State water quality standards specify water quality criteria that is deemed necessary to support the use classifications These criteria may by numerical or narrative The water quality criteria applicable to the proposed permit are provided in Appendix C (Section IIIA) These criteria provide the basis for most of the effluent limits in the draft permit
Portions of Thompson Creek and the Salmon River are listed on Idahorsquos 303(d) list (a list of impaired waters compiled under Section 303(d) of the Clean Water Act) The 303(d) list identifies water bodies that do not meet or are not expected to meet water quality standards
Specifically these waters were listed as not meeting standards for
8
Thompson Creek (about three miles downstream from Outfall 002 to the confluence with the Salmon River) - sediment and metals
Salmon River (including the discharge location) - sediment and temperature
Section 303(d) of the Clean Water Act (CWA) requires States to develop a Total Maximum Daily Load (TMDL) management plan for water bodies on the 303(d) list A TMDL allocates loading capacities to point and nonpoint sources to the water body Permit limits for point sources must be consistent with applicable TMDL allocations A TMDL for Thompson Creek and this part of the Salmon River is scheduled to be completed in 2001 The General Provisions section of the draft permit contains a provision to allow EPA to reopen the permit (eg to incorporate any applicable effluent limitations and conditions which may result from final TMDLs on these receiving waters)
V EFFLUENT LIMITATIONS
EPA followed the Clean Water Act (CWA) state and federal regulations and EPArsquos 1991 Technical Support Document for Water Quality-Based Toxics Control (TSD) to develop the effluent limits in the draft permit In general the CWA requires that the effluent limit for a particular pollutant be the more stringent of either the technology-based limit or water quality-based limit Appendix C provides discussion on the legal basis for the development of technology-based and water quality-based effluent limits
EPA sets technology-based limits based on the effluent quality that is achievable using readily available technology The Agency evaluates the technology-based limits to determine whether they are adequate to ensure that water quality standards are met in the receiving water If the limits are not adequate EPA must develop additional water quality-based limits Water quality-based limits are designed to prevent exceedances of the Idaho water quality standards in the receiving waters
The proposed permit includes technology-based limits for total suspended solids (TSS) water quality-based and technology-based limits for pH and water quality-based limits for most metals Tables 2 and 3 compare the existing effluent limits for outfalls 001 and 002 with the proposed effluent limits in the draft permit Tables 4 and 5 include the proposed effluent limits for the new discharges from outfalls 004 and 005 Appendix C describes in detail how the effluent limits were developed
Two sets of limits (tiered limits) were developed for outfalls 001 002 and 004 to allow for seasonal variability of the flows in the receiving waters Except for pH and TSS the proposed effluent limits are expressed in terms of both mass (poundsday) and concentration (ugl) for outfalls 004 and 005 Establishment of mass-based limits ensures that total loadings to the receiving waters are controlled Mass limits were not calculated for outfalls 001 and 002 since the effluent flow from these outfalls is dependent upon precipitation and varies with the
9
receiving water flow Concentration-based limits for these outfalls were calculated based on the ratio of effluent flow to receiving water flow (the dilution ratio) for each flow tier Therefore mass loadings for these outfalls will be controlled by limiting the dilution ratio consistent with the dilution ratio used to develop the concentration-based effluent limits (see also Section IV of Appendix C)
Effluent limits were not developed for Outfall 003 Rather ldquobest management practicesrdquo (BMPs) and monitoring are the permit conditions used to address storm water (see Sections VIC and VIIB of this fact sheet)
Table 2 Effluent Limitations for Outfall 001
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1 none -shy -shy 0011 0011 0092 0092
arsenic ugl 490 -shy -shy -shy ndash ndash
cadmium ugl 532 ndash 35 24 68 47
copper ugl 2452 -shy 270 180 31 21
lead ugl 5892 -shy 94 64 19 13
mercury ugl 022 -shy 046 032 0073 0050
selenium ugl -shy -shy 1505 1105 425 305
zinc ugl 1652 -shy 1500 750 210 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals are to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
10
Table 3 Effluent Limitations for Outfall 002
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1
none -shy -shy 0085 0085 018 018
arsenic ugl 490 -shy -shy -shy -shy -shy
cadmium ugl 532 ndash 11 78 52 35
copper ugl 2452 -shy 53 36 22 15
lead ugl 5892 -shy 31 21 12 83
mercury ugl 022 -shy 0077 0053 0047 0032
selenium ugl -shy -shy 235 165 175 115
zinc ugl 1652 -shy 290 200 220 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
11
Table 4 Effluent Limitations for Outfall 004
Parameter units Proposed Effluent Limitations1
at Squaw Creek flow lt 50 cfs2 at Squaw Creek flow $ 50 cfs2
Maximum Daily Monthly Average Maximum Daily Monthly Average
cadmium ugl 12 58 26 13
lbday 0084 0041 018 0091
chromium ugl 40 20 -shy -shy
lbday 028 014 -shy -shy
copper ugl 48 24 120 58
lbday 034 017 084 041
lead ugl 37 18 21 10
lbday 026 013 015 0070
mercury ugl 0037 0018 021 010
lbday 000026 000013 00015 000070
silver ugl -shy -shy 22 11
lbday -shy -shy 015 0077
zinc ugl 290 140 860 430
lbday 20 098 60 30
TSS mgl 30 20 30 20
pH su within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be total 2 - The flow tiers are representative of flow upstream of the outfall
12
Table 5 Effluent Limitations for Outfall 005
Parameter units Proposed Effluent Limitationss
Maximum Daily Monthly Average
cadmium ugl 12 62
lbday 017 0090
copper ugl 120 59
lbday 17 086
lead ugl 21 10
lbday 030 015
mercury ugl 061 030
lbday 00089 00044
silver ugl 12 60
lbday 017 0087
zinc ugl 1000 500
lbday 15 73
TSS mgl 30 20
pH su within the range of 65 - 90
Footnote 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total
VI MONITORING REQUIREMENTS
Section 308 of the Clean Water Act and federal regulation 40 CFR 12244(i) require that monitoring be included in permits to determine compliance with effluent limitations Monitoring may also be required to gather data for future effluent limitations or to monitor effluent impacts on receiving water quality TCMC is responsible for conducting the monitoring and reporting the results to EPA on monthly DMRs and in annual reports This section describes the monitoring requirements in the draft permit
A Effluent Monitoring
The effluent monitoring requirements in the draft permit are summarized in Table 6 The monitoring frequency for outfalls 001 and 002 is the same as included in the current permit (monthly for most parameters) The monitoring frequency for most of the outfall 004 and 005
13
parameters is weekly More frequent monitoring and composite sampling was determined to be necessary for these outfalls due to the composition of the outfalls (process water) the more continuous nature of the discharges and the Special Resource status of the Salmon River (Outfall 005) Flow monitoring of the receiving waters is required for outfalls 001 002 and 004 to determine which set of tiered effluent limits apply and to calculate dilution ratios (outfalls 001 and 002 only) Monitoring of Outfall 003 is discussed in Section VIC below
Some of the water quality-based effluent limits in the draft permit are close to the capability of current analytical technology to detect andor quantify (close to method detection limits) To address this concern the draft permit contains a provision requiring TCMC to use analytical methods that can achieve a method detection limit less than the effluent limitation Method detection limits are the minimum levels that can be accurately detected by current analytical technology
Table 6 Effluent Monitoring Requirements
Parameter Outfalls 001 and 002 Outfalls 004 and 005
frequency sample type frequency sample type
dilution ratio daily calculation -shy -shy
outfall flow cfs continuous recording continuous recording
metals with effluent limits1 ugl monthly grab weekly 24-hour composite
molybdenum ugl quarterly grab quarterly 24-hour composite
selenium2 ugl monthly grab quarterly 24-hour composite
TSS mgl weekly grab weekly 24-hour composite
pH standard units (su) weekly grab daily grab
hardness as CaCO3 mgl monthly grab weekly 24-hour composite
temperature oC weekly grab weekly grab
Acute WET3 TUa annually grab annually 24-hour composite
Chronic WET3 TUc annually grab quarterly 24-hour composite
Thompson Creek Flow4 cfs daily recording daily recording
Squaw Creek Flow5 cfs daily recording daily recording
Footnotes 1 - metals to be measured include cadmium chromium (outfall 004 only) copper lead mercury selenium (outfalls 001 and 002 only) silver (outfalls 004 and 005 only) and zinc 2 - selenium monitoring required for outfalls 001 and 002 (see footnote 1) and 005 3 - See Section VIB below for specific information regarding the whole effluent toxicity (WET) monitoring 4 - Thompson Creek flow monitoring is required upstream of each outfalls 001 and 002 5 - Squaw Creek flow monitoring is required upstream of Outfall 004
14
B Whole Effluent Toxicity Testing
Whole effluent toxicity (WET) is defined as the aggregate toxic effect of an effluent measured directly by an aquatic toxicity test WET tests are standardized laboratory tests that measure the total toxic effect of an effluent by exposing organisms to the effluent and noting the effects There are two different durations of toxicity tests acute and chronic Acute toxicity tests measure the test organisms survival over a 96-hour test exposure period Chronic toxicity tests measure reductions in survival growth and reproduction over a 7-day exposure
TCMC has conducted limited WET testing on their effluents In 1993 one set of WET tests were performed on effluent from outfalls 001 and 002 and some of the sources of wastewater to outfalls 004 and 005 (LA and PBS wastewaters) Results indicated no acute toxicity Chronic toxicity was indicated for Outfall 001 and the LA and PBS wastewaters at 100 effluent however the tests were not performed at dilutions representing the mixing zones In 1999 TCMC conducted an additional set of WET tests on outfalls 001 and 002 These tests indicated no acute toxicity Chronic toxicity was indicated for one species tested on Outfall 002
Federal regulations at 40 CFR 12244(d)(1) require that permits contain limits on WET when a discharge has reasonable potential to cause or contribute to an exceedence of a water quality standard In Idaho the relevant water quality standard states that surface waters of the State shall be free from toxic substances in concentrations that impair designated beneficial uses (see Appendix C Table C-2) The TSD provides guidance on implementing WET testing in NPDES permits The preliminary CWA Section 401 Certification provided by IDEQ included specific WET testing requirements for this permit (see also Section VIIIB)
Because the limited amount of existing WET testing on the TCM effluents is not adequate to determine the need for WET effluent limits WET testing has been incorporated into the draft permit The draft permit requires TCMC to conduct acute WET testing annually on effluent from each outfall Chronic WET testing must be conducted annually for outfalls 001 and 002 and quarterly for outfalls 004 and 005 TCMC is required to perform the acute tests using the salmonid species Oncorhynchus mykiss (rainbow trout) and the chronic tests using both Pimephales promelas (fathead minnow) and Ceriodaphnia dubia (water fleas) Different species are used for testing to represent different aquatic phyla (fish and invertebrates) and because different species have different sensitivities The tests will be conducted at a range of dilutions that mimic the effluent-receiving water mixing conditions Results of these tests will be used to ensure that toxics in the effluent are controlled and to determine the need for future WET limits In addition the permit establishes toxicity trigger levels for each outfall (see Appendix C Section IVB ) that if exceeded trigger additional WET testing and potentially investigations to reduce toxicity
C Storm Water Monitoring
The current permit requires TCMC to monitor the receiving water upstream and downstream of the Outfall 003 sediment ponds for turbidity The monitoring is specified as weekly during
15
February through June and monthly for the other months of the year The draft permit continues this turbidity monitoring In addition the draft permit requires daily monitoring of effluent flow and monthly monitoring of Outfall 003 for metals (cadmium copper lead mercury and zinc) hardness TSS pH and temperature to ensure that water quality standards are maintained
The storm water discharge should not adversely affect water quality This assumes appropriate design and implementation of best management practices (BMPs) in lieu of numerical effluent limits The monitoring required in the draft permit along with periodic inspections are required to evaluate the effectiveness of BMPs and to provide sufficient information to determine if these discharges either cause or contribute to water quality standards exceedences Section VIIB below discusses the BMP requirements
D Receiving Water Monitoring
The current permit requires TCMC to provide for water quality monitoring in accordance with the program agreed upon by the Interagency Task Force (members of which include the USFS BLM IDEQ EPA and TCMC) TCMCrsquos current environmental monitoring program is described in the Consolidated Environmental Monitoring Program (TCMC 1999a) This program includes monitoring of the surface water sediments and aquatic biology in the receiving waters
The draft permit requires TCMC to continue this monitoring as it relates to the permitted discharges by specifying monitoring at selected locations within and around the discharge areas The water quality monitoring requirements in the draft permit are for the most part consistent with TCMCrsquos Consolidated Monitoring Program However some additional monitoring has been added since two new outfalls are proposed (004 and 005) one of the new outfalls (005) discharges to a Special Resource Water and to verify that bioaccumulation is not of concern The following summarizes the monitoring requirements in the draft permit
Surface Water Quality Monitoring Surface water quality monitoring of the receiving waters is required four times per year upstream and downstream of each outfall for the parameters listed in Table 7 When there is a discharge from outfalls 004 or 005 the permit requires that the monitoring frequency for metals in the Salmon River be increased to monthly This was a requirement of IDEQrsquos preliminary CWA Section 401 Certification for discharge into a Special Resource Water (see also Section VIIIB) IDEQ also required that for each sampling event metals concentrations in the receiving water be compared to aquatic life chronic water quality criteria If the concentrations exceed the criteria then future sampling for that parameter will be expanded to determine 4-day average concentrations (since chronic criteria are expressed as 4shyday average concentrations)
The receiving water quality monitoring data is used to evaluate the water quality impacts of the NPDES discharges The data will also be used during the next permitting cycle to determine the need for incorporating and retaining water quality-based effluent limits into the permit In order to perform these evaluations it is necessary that the ambient monitoring use analytical methods
16
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 6: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/6.jpg)
I APPLICANT
Thompson Creek Mining Company NPDES Permit No ID-002540-2
Mailing Address
Facility Location
PO Box 62 Clayton Idaho 83227 See Figure A-1 in Appendix A
Facility Contact Bert Doughty Supervisor Environmental Affairs (208) 838-2200
II FACILITY ACTIVITY
The Thompson Creek Mine (TCM) is a molybdenum mine and mill located in Custer County Idaho approximately 30 miles southwest of Challis (see Figure A-1) The mine and mill are owned and operated by the Thompson Creek Mining Company (TCMC) The facility has been in operation since 1983 with periods of temporary closure in 1991 and from December 1992 to April 1994 At the current processing rate of 28000 to 32000 tpd the life of the TCM is estimated at 15 years
The mine facilities encompass approximately 2400 acres on both private lands and public lands The federal land area is managed by the US Forest Service (Salmon-Challis National Forest) and the US Bureau of Land Management (Challis Resource Area) The mine facilities are located in the Bruno Creek Buckskin Creek and Pat Hughes Creek drainages These creeks are tributaries to Thompson and Squaw creeks which flow into the Salmon River approximately 5 miles from the mine site (see Figure A-1)
Molybdenum ore is mined via open pit methods At the mill the ore is processed by flotation to produce a molybdenum concentrate The molybdenum concentrate is transported off-site for refining Tailings (the residuals from flotation) are piped in a slurry from the mill to the tailings impoundment The tailings impoundment is constructed in the upper Bruno Creek watershed and covers approximately 280 acres The impoundment currently contains approximately 90 million tons of tailings Waste rock (rock that is removed from the mine in order to gain access to the ore) is hauled from the mine for disposal in either the Pat Hughes or Buckskin waste rock dumps To-date approximately 350 million tons of waste rock have been disposed in the Buckskin Creek dump and 50 million tons in the Pat Hughes dump More detailed information on the TCM operations can be found in the Supplemental Plan of Operations (TCMC 1998)
The facility currently discharges wastewater from the Buckskin and Pat Hughes waste rock dumps through two outfalls (001 and 002) and storm water through Outfall 003 The proposed permit will allow discharge through two new outfalls (004 and 005) from the tailings impoundment in the event of excess precipitation or mine closure In addition wastewater from Outfalls 001 and 002 may be discharged instead out of Outfall 005 The parameters of concern
6
in the discharges include pH total suspended solids (TSS) and metals The following table summarizes each outfall A more detailed description of each outfall is proved in Appendix B A map of the outfall locations is provided in Appendix A (Figure A-2)
Table 1 Proposed NPDES Outfalls
Outfall Receiving Water Description of Discharge1 Flow Rate2
001 Thompson Creek seepage and runoff from the Buckskin waste rock dump
discharge generally occurs in April-July only calculated avg discharge = 12 cfs measured max discharge = 84 cfs
002 Thompson Creek seepage and runoff from the Pat Hughes waste rock dump
discharge continuous peaks in May - July calculated avg discharge = 07 cfs measured max discharge = 12 cfs
003 Squaw Creek storm water mine road runoff Bruno Creek diversion
discharge continuous peaks in May - July calculated avg discharge = 11 cfs measured max discharge = 97 cfs
004 Squaw Creek tailings impoundment seepage predicted max discharge = 13 cfs
005 Salmon River tailings impoundment seepage and open pit mine water3
predicted max discharge = 27 cfs
Footnotes 1 - See also Appendix B 2 - Flows are based on the last five years of monitoring conducted by TCMC 3 - TCMC may discharge effluent from outfalls 001 and 002 out of Outfall 005
III FACILITY BACKGROUND
A Permit History
EPA first issued a National Pollutant Discharge Elimination System (NPDES) permit for the TCM on June 10 1981 The current permit was reissued by EPA on August 1 1988 The current permit expired on August 2 1993 A timely application for renewal of the permit and for establishment of Outfall 004 was submitted to EPA on September 17 1992 A revised application for establishment of Outfall 005 was submitted on September 7 1993 A second revised application for Outfalls 001 and 002 (applying to discharge from either the original outfall locations or the Outfall 005 location) was submitted to EPA on February 22 2000 Additional information related to this permit reissuance was submitted by TCMC to EPA on September 1 1999 September 21 1999 and February 22 2000 Because the Permittee submitted a timely application for renewal the 1988 permit has been administratively extended and remains fully effective and enforceable until reissuance
7
On July 14 1994 a draft NPDES Permit for the TCM was issued for public notice The effluent limits for metals in the July 1994 draft permit were based on State of Idaho water quality criteria that were expressed as total recoverable While EPA was finalizing the permit the State of Idaho adopted new water quality criteria that express some metals as dissolved In addition a new criteria for arsenic was promulgated To accommodate these changes and the new information submitted by TCMC this new draft permit has been prepared and is being reissued for public comment
B Compliance History
TCMC submits monthly discharge monitoring reports (DMRs) to EPA summarizing the results of effluent monitoring required by the permit The following effluent limit violations were noted based on review of the past five yearsrsquo DMRs
Outfall 001 In June and July 1995 pH was reported at 91 (outside the pH limit of 6 - 9)
Outfall 002 Violations of the maximum daily effluent limits were reported in March 1999 (TSS only) May 1999 (TSS and zinc) and August 1999 (cadmium and zinc) TCMC attributed the March violation to heavy snow pack and the subsequent violations to a break in the pit diversion line located beneath the waste rock dump TCMC stopped discharging while investigating and fixing the break The diversion line has since been fixed and discharges are within the effluent limits
IV RECEIVING WATERS
As discussed in Section II the TCM outfalls discharge to Squaw Creek Thompson Creek and the Salmon River The Idaho Water Quality Standards and Wastewater Treatment Requirements designate beneficial uses for waters of the State These three waters are classified by the State of Idaho for protection of the following uses (1) agricultural water supply (2) cold water biota (3) salmonid spawning and (4) secondary contact recreation In addition the Salmon River is protected for domestic water supply and primary contact recreation and is classified as a Special Resource Water
The State water quality standards specify water quality criteria that is deemed necessary to support the use classifications These criteria may by numerical or narrative The water quality criteria applicable to the proposed permit are provided in Appendix C (Section IIIA) These criteria provide the basis for most of the effluent limits in the draft permit
Portions of Thompson Creek and the Salmon River are listed on Idahorsquos 303(d) list (a list of impaired waters compiled under Section 303(d) of the Clean Water Act) The 303(d) list identifies water bodies that do not meet or are not expected to meet water quality standards
Specifically these waters were listed as not meeting standards for
8
Thompson Creek (about three miles downstream from Outfall 002 to the confluence with the Salmon River) - sediment and metals
Salmon River (including the discharge location) - sediment and temperature
Section 303(d) of the Clean Water Act (CWA) requires States to develop a Total Maximum Daily Load (TMDL) management plan for water bodies on the 303(d) list A TMDL allocates loading capacities to point and nonpoint sources to the water body Permit limits for point sources must be consistent with applicable TMDL allocations A TMDL for Thompson Creek and this part of the Salmon River is scheduled to be completed in 2001 The General Provisions section of the draft permit contains a provision to allow EPA to reopen the permit (eg to incorporate any applicable effluent limitations and conditions which may result from final TMDLs on these receiving waters)
V EFFLUENT LIMITATIONS
EPA followed the Clean Water Act (CWA) state and federal regulations and EPArsquos 1991 Technical Support Document for Water Quality-Based Toxics Control (TSD) to develop the effluent limits in the draft permit In general the CWA requires that the effluent limit for a particular pollutant be the more stringent of either the technology-based limit or water quality-based limit Appendix C provides discussion on the legal basis for the development of technology-based and water quality-based effluent limits
EPA sets technology-based limits based on the effluent quality that is achievable using readily available technology The Agency evaluates the technology-based limits to determine whether they are adequate to ensure that water quality standards are met in the receiving water If the limits are not adequate EPA must develop additional water quality-based limits Water quality-based limits are designed to prevent exceedances of the Idaho water quality standards in the receiving waters
The proposed permit includes technology-based limits for total suspended solids (TSS) water quality-based and technology-based limits for pH and water quality-based limits for most metals Tables 2 and 3 compare the existing effluent limits for outfalls 001 and 002 with the proposed effluent limits in the draft permit Tables 4 and 5 include the proposed effluent limits for the new discharges from outfalls 004 and 005 Appendix C describes in detail how the effluent limits were developed
Two sets of limits (tiered limits) were developed for outfalls 001 002 and 004 to allow for seasonal variability of the flows in the receiving waters Except for pH and TSS the proposed effluent limits are expressed in terms of both mass (poundsday) and concentration (ugl) for outfalls 004 and 005 Establishment of mass-based limits ensures that total loadings to the receiving waters are controlled Mass limits were not calculated for outfalls 001 and 002 since the effluent flow from these outfalls is dependent upon precipitation and varies with the
9
receiving water flow Concentration-based limits for these outfalls were calculated based on the ratio of effluent flow to receiving water flow (the dilution ratio) for each flow tier Therefore mass loadings for these outfalls will be controlled by limiting the dilution ratio consistent with the dilution ratio used to develop the concentration-based effluent limits (see also Section IV of Appendix C)
Effluent limits were not developed for Outfall 003 Rather ldquobest management practicesrdquo (BMPs) and monitoring are the permit conditions used to address storm water (see Sections VIC and VIIB of this fact sheet)
Table 2 Effluent Limitations for Outfall 001
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1 none -shy -shy 0011 0011 0092 0092
arsenic ugl 490 -shy -shy -shy ndash ndash
cadmium ugl 532 ndash 35 24 68 47
copper ugl 2452 -shy 270 180 31 21
lead ugl 5892 -shy 94 64 19 13
mercury ugl 022 -shy 046 032 0073 0050
selenium ugl -shy -shy 1505 1105 425 305
zinc ugl 1652 -shy 1500 750 210 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals are to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
10
Table 3 Effluent Limitations for Outfall 002
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1
none -shy -shy 0085 0085 018 018
arsenic ugl 490 -shy -shy -shy -shy -shy
cadmium ugl 532 ndash 11 78 52 35
copper ugl 2452 -shy 53 36 22 15
lead ugl 5892 -shy 31 21 12 83
mercury ugl 022 -shy 0077 0053 0047 0032
selenium ugl -shy -shy 235 165 175 115
zinc ugl 1652 -shy 290 200 220 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
11
Table 4 Effluent Limitations for Outfall 004
Parameter units Proposed Effluent Limitations1
at Squaw Creek flow lt 50 cfs2 at Squaw Creek flow $ 50 cfs2
Maximum Daily Monthly Average Maximum Daily Monthly Average
cadmium ugl 12 58 26 13
lbday 0084 0041 018 0091
chromium ugl 40 20 -shy -shy
lbday 028 014 -shy -shy
copper ugl 48 24 120 58
lbday 034 017 084 041
lead ugl 37 18 21 10
lbday 026 013 015 0070
mercury ugl 0037 0018 021 010
lbday 000026 000013 00015 000070
silver ugl -shy -shy 22 11
lbday -shy -shy 015 0077
zinc ugl 290 140 860 430
lbday 20 098 60 30
TSS mgl 30 20 30 20
pH su within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be total 2 - The flow tiers are representative of flow upstream of the outfall
12
Table 5 Effluent Limitations for Outfall 005
Parameter units Proposed Effluent Limitationss
Maximum Daily Monthly Average
cadmium ugl 12 62
lbday 017 0090
copper ugl 120 59
lbday 17 086
lead ugl 21 10
lbday 030 015
mercury ugl 061 030
lbday 00089 00044
silver ugl 12 60
lbday 017 0087
zinc ugl 1000 500
lbday 15 73
TSS mgl 30 20
pH su within the range of 65 - 90
Footnote 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total
VI MONITORING REQUIREMENTS
Section 308 of the Clean Water Act and federal regulation 40 CFR 12244(i) require that monitoring be included in permits to determine compliance with effluent limitations Monitoring may also be required to gather data for future effluent limitations or to monitor effluent impacts on receiving water quality TCMC is responsible for conducting the monitoring and reporting the results to EPA on monthly DMRs and in annual reports This section describes the monitoring requirements in the draft permit
A Effluent Monitoring
The effluent monitoring requirements in the draft permit are summarized in Table 6 The monitoring frequency for outfalls 001 and 002 is the same as included in the current permit (monthly for most parameters) The monitoring frequency for most of the outfall 004 and 005
13
parameters is weekly More frequent monitoring and composite sampling was determined to be necessary for these outfalls due to the composition of the outfalls (process water) the more continuous nature of the discharges and the Special Resource status of the Salmon River (Outfall 005) Flow monitoring of the receiving waters is required for outfalls 001 002 and 004 to determine which set of tiered effluent limits apply and to calculate dilution ratios (outfalls 001 and 002 only) Monitoring of Outfall 003 is discussed in Section VIC below
Some of the water quality-based effluent limits in the draft permit are close to the capability of current analytical technology to detect andor quantify (close to method detection limits) To address this concern the draft permit contains a provision requiring TCMC to use analytical methods that can achieve a method detection limit less than the effluent limitation Method detection limits are the minimum levels that can be accurately detected by current analytical technology
Table 6 Effluent Monitoring Requirements
Parameter Outfalls 001 and 002 Outfalls 004 and 005
frequency sample type frequency sample type
dilution ratio daily calculation -shy -shy
outfall flow cfs continuous recording continuous recording
metals with effluent limits1 ugl monthly grab weekly 24-hour composite
molybdenum ugl quarterly grab quarterly 24-hour composite
selenium2 ugl monthly grab quarterly 24-hour composite
TSS mgl weekly grab weekly 24-hour composite
pH standard units (su) weekly grab daily grab
hardness as CaCO3 mgl monthly grab weekly 24-hour composite
temperature oC weekly grab weekly grab
Acute WET3 TUa annually grab annually 24-hour composite
Chronic WET3 TUc annually grab quarterly 24-hour composite
Thompson Creek Flow4 cfs daily recording daily recording
Squaw Creek Flow5 cfs daily recording daily recording
Footnotes 1 - metals to be measured include cadmium chromium (outfall 004 only) copper lead mercury selenium (outfalls 001 and 002 only) silver (outfalls 004 and 005 only) and zinc 2 - selenium monitoring required for outfalls 001 and 002 (see footnote 1) and 005 3 - See Section VIB below for specific information regarding the whole effluent toxicity (WET) monitoring 4 - Thompson Creek flow monitoring is required upstream of each outfalls 001 and 002 5 - Squaw Creek flow monitoring is required upstream of Outfall 004
14
B Whole Effluent Toxicity Testing
Whole effluent toxicity (WET) is defined as the aggregate toxic effect of an effluent measured directly by an aquatic toxicity test WET tests are standardized laboratory tests that measure the total toxic effect of an effluent by exposing organisms to the effluent and noting the effects There are two different durations of toxicity tests acute and chronic Acute toxicity tests measure the test organisms survival over a 96-hour test exposure period Chronic toxicity tests measure reductions in survival growth and reproduction over a 7-day exposure
TCMC has conducted limited WET testing on their effluents In 1993 one set of WET tests were performed on effluent from outfalls 001 and 002 and some of the sources of wastewater to outfalls 004 and 005 (LA and PBS wastewaters) Results indicated no acute toxicity Chronic toxicity was indicated for Outfall 001 and the LA and PBS wastewaters at 100 effluent however the tests were not performed at dilutions representing the mixing zones In 1999 TCMC conducted an additional set of WET tests on outfalls 001 and 002 These tests indicated no acute toxicity Chronic toxicity was indicated for one species tested on Outfall 002
Federal regulations at 40 CFR 12244(d)(1) require that permits contain limits on WET when a discharge has reasonable potential to cause or contribute to an exceedence of a water quality standard In Idaho the relevant water quality standard states that surface waters of the State shall be free from toxic substances in concentrations that impair designated beneficial uses (see Appendix C Table C-2) The TSD provides guidance on implementing WET testing in NPDES permits The preliminary CWA Section 401 Certification provided by IDEQ included specific WET testing requirements for this permit (see also Section VIIIB)
Because the limited amount of existing WET testing on the TCM effluents is not adequate to determine the need for WET effluent limits WET testing has been incorporated into the draft permit The draft permit requires TCMC to conduct acute WET testing annually on effluent from each outfall Chronic WET testing must be conducted annually for outfalls 001 and 002 and quarterly for outfalls 004 and 005 TCMC is required to perform the acute tests using the salmonid species Oncorhynchus mykiss (rainbow trout) and the chronic tests using both Pimephales promelas (fathead minnow) and Ceriodaphnia dubia (water fleas) Different species are used for testing to represent different aquatic phyla (fish and invertebrates) and because different species have different sensitivities The tests will be conducted at a range of dilutions that mimic the effluent-receiving water mixing conditions Results of these tests will be used to ensure that toxics in the effluent are controlled and to determine the need for future WET limits In addition the permit establishes toxicity trigger levels for each outfall (see Appendix C Section IVB ) that if exceeded trigger additional WET testing and potentially investigations to reduce toxicity
C Storm Water Monitoring
The current permit requires TCMC to monitor the receiving water upstream and downstream of the Outfall 003 sediment ponds for turbidity The monitoring is specified as weekly during
15
February through June and monthly for the other months of the year The draft permit continues this turbidity monitoring In addition the draft permit requires daily monitoring of effluent flow and monthly monitoring of Outfall 003 for metals (cadmium copper lead mercury and zinc) hardness TSS pH and temperature to ensure that water quality standards are maintained
The storm water discharge should not adversely affect water quality This assumes appropriate design and implementation of best management practices (BMPs) in lieu of numerical effluent limits The monitoring required in the draft permit along with periodic inspections are required to evaluate the effectiveness of BMPs and to provide sufficient information to determine if these discharges either cause or contribute to water quality standards exceedences Section VIIB below discusses the BMP requirements
D Receiving Water Monitoring
The current permit requires TCMC to provide for water quality monitoring in accordance with the program agreed upon by the Interagency Task Force (members of which include the USFS BLM IDEQ EPA and TCMC) TCMCrsquos current environmental monitoring program is described in the Consolidated Environmental Monitoring Program (TCMC 1999a) This program includes monitoring of the surface water sediments and aquatic biology in the receiving waters
The draft permit requires TCMC to continue this monitoring as it relates to the permitted discharges by specifying monitoring at selected locations within and around the discharge areas The water quality monitoring requirements in the draft permit are for the most part consistent with TCMCrsquos Consolidated Monitoring Program However some additional monitoring has been added since two new outfalls are proposed (004 and 005) one of the new outfalls (005) discharges to a Special Resource Water and to verify that bioaccumulation is not of concern The following summarizes the monitoring requirements in the draft permit
Surface Water Quality Monitoring Surface water quality monitoring of the receiving waters is required four times per year upstream and downstream of each outfall for the parameters listed in Table 7 When there is a discharge from outfalls 004 or 005 the permit requires that the monitoring frequency for metals in the Salmon River be increased to monthly This was a requirement of IDEQrsquos preliminary CWA Section 401 Certification for discharge into a Special Resource Water (see also Section VIIIB) IDEQ also required that for each sampling event metals concentrations in the receiving water be compared to aquatic life chronic water quality criteria If the concentrations exceed the criteria then future sampling for that parameter will be expanded to determine 4-day average concentrations (since chronic criteria are expressed as 4shyday average concentrations)
The receiving water quality monitoring data is used to evaluate the water quality impacts of the NPDES discharges The data will also be used during the next permitting cycle to determine the need for incorporating and retaining water quality-based effluent limits into the permit In order to perform these evaluations it is necessary that the ambient monitoring use analytical methods
16
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 7: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/7.jpg)
in the discharges include pH total suspended solids (TSS) and metals The following table summarizes each outfall A more detailed description of each outfall is proved in Appendix B A map of the outfall locations is provided in Appendix A (Figure A-2)
Table 1 Proposed NPDES Outfalls
Outfall Receiving Water Description of Discharge1 Flow Rate2
001 Thompson Creek seepage and runoff from the Buckskin waste rock dump
discharge generally occurs in April-July only calculated avg discharge = 12 cfs measured max discharge = 84 cfs
002 Thompson Creek seepage and runoff from the Pat Hughes waste rock dump
discharge continuous peaks in May - July calculated avg discharge = 07 cfs measured max discharge = 12 cfs
003 Squaw Creek storm water mine road runoff Bruno Creek diversion
discharge continuous peaks in May - July calculated avg discharge = 11 cfs measured max discharge = 97 cfs
004 Squaw Creek tailings impoundment seepage predicted max discharge = 13 cfs
005 Salmon River tailings impoundment seepage and open pit mine water3
predicted max discharge = 27 cfs
Footnotes 1 - See also Appendix B 2 - Flows are based on the last five years of monitoring conducted by TCMC 3 - TCMC may discharge effluent from outfalls 001 and 002 out of Outfall 005
III FACILITY BACKGROUND
A Permit History
EPA first issued a National Pollutant Discharge Elimination System (NPDES) permit for the TCM on June 10 1981 The current permit was reissued by EPA on August 1 1988 The current permit expired on August 2 1993 A timely application for renewal of the permit and for establishment of Outfall 004 was submitted to EPA on September 17 1992 A revised application for establishment of Outfall 005 was submitted on September 7 1993 A second revised application for Outfalls 001 and 002 (applying to discharge from either the original outfall locations or the Outfall 005 location) was submitted to EPA on February 22 2000 Additional information related to this permit reissuance was submitted by TCMC to EPA on September 1 1999 September 21 1999 and February 22 2000 Because the Permittee submitted a timely application for renewal the 1988 permit has been administratively extended and remains fully effective and enforceable until reissuance
7
On July 14 1994 a draft NPDES Permit for the TCM was issued for public notice The effluent limits for metals in the July 1994 draft permit were based on State of Idaho water quality criteria that were expressed as total recoverable While EPA was finalizing the permit the State of Idaho adopted new water quality criteria that express some metals as dissolved In addition a new criteria for arsenic was promulgated To accommodate these changes and the new information submitted by TCMC this new draft permit has been prepared and is being reissued for public comment
B Compliance History
TCMC submits monthly discharge monitoring reports (DMRs) to EPA summarizing the results of effluent monitoring required by the permit The following effluent limit violations were noted based on review of the past five yearsrsquo DMRs
Outfall 001 In June and July 1995 pH was reported at 91 (outside the pH limit of 6 - 9)
Outfall 002 Violations of the maximum daily effluent limits were reported in March 1999 (TSS only) May 1999 (TSS and zinc) and August 1999 (cadmium and zinc) TCMC attributed the March violation to heavy snow pack and the subsequent violations to a break in the pit diversion line located beneath the waste rock dump TCMC stopped discharging while investigating and fixing the break The diversion line has since been fixed and discharges are within the effluent limits
IV RECEIVING WATERS
As discussed in Section II the TCM outfalls discharge to Squaw Creek Thompson Creek and the Salmon River The Idaho Water Quality Standards and Wastewater Treatment Requirements designate beneficial uses for waters of the State These three waters are classified by the State of Idaho for protection of the following uses (1) agricultural water supply (2) cold water biota (3) salmonid spawning and (4) secondary contact recreation In addition the Salmon River is protected for domestic water supply and primary contact recreation and is classified as a Special Resource Water
The State water quality standards specify water quality criteria that is deemed necessary to support the use classifications These criteria may by numerical or narrative The water quality criteria applicable to the proposed permit are provided in Appendix C (Section IIIA) These criteria provide the basis for most of the effluent limits in the draft permit
Portions of Thompson Creek and the Salmon River are listed on Idahorsquos 303(d) list (a list of impaired waters compiled under Section 303(d) of the Clean Water Act) The 303(d) list identifies water bodies that do not meet or are not expected to meet water quality standards
Specifically these waters were listed as not meeting standards for
8
Thompson Creek (about three miles downstream from Outfall 002 to the confluence with the Salmon River) - sediment and metals
Salmon River (including the discharge location) - sediment and temperature
Section 303(d) of the Clean Water Act (CWA) requires States to develop a Total Maximum Daily Load (TMDL) management plan for water bodies on the 303(d) list A TMDL allocates loading capacities to point and nonpoint sources to the water body Permit limits for point sources must be consistent with applicable TMDL allocations A TMDL for Thompson Creek and this part of the Salmon River is scheduled to be completed in 2001 The General Provisions section of the draft permit contains a provision to allow EPA to reopen the permit (eg to incorporate any applicable effluent limitations and conditions which may result from final TMDLs on these receiving waters)
V EFFLUENT LIMITATIONS
EPA followed the Clean Water Act (CWA) state and federal regulations and EPArsquos 1991 Technical Support Document for Water Quality-Based Toxics Control (TSD) to develop the effluent limits in the draft permit In general the CWA requires that the effluent limit for a particular pollutant be the more stringent of either the technology-based limit or water quality-based limit Appendix C provides discussion on the legal basis for the development of technology-based and water quality-based effluent limits
EPA sets technology-based limits based on the effluent quality that is achievable using readily available technology The Agency evaluates the technology-based limits to determine whether they are adequate to ensure that water quality standards are met in the receiving water If the limits are not adequate EPA must develop additional water quality-based limits Water quality-based limits are designed to prevent exceedances of the Idaho water quality standards in the receiving waters
The proposed permit includes technology-based limits for total suspended solids (TSS) water quality-based and technology-based limits for pH and water quality-based limits for most metals Tables 2 and 3 compare the existing effluent limits for outfalls 001 and 002 with the proposed effluent limits in the draft permit Tables 4 and 5 include the proposed effluent limits for the new discharges from outfalls 004 and 005 Appendix C describes in detail how the effluent limits were developed
Two sets of limits (tiered limits) were developed for outfalls 001 002 and 004 to allow for seasonal variability of the flows in the receiving waters Except for pH and TSS the proposed effluent limits are expressed in terms of both mass (poundsday) and concentration (ugl) for outfalls 004 and 005 Establishment of mass-based limits ensures that total loadings to the receiving waters are controlled Mass limits were not calculated for outfalls 001 and 002 since the effluent flow from these outfalls is dependent upon precipitation and varies with the
9
receiving water flow Concentration-based limits for these outfalls were calculated based on the ratio of effluent flow to receiving water flow (the dilution ratio) for each flow tier Therefore mass loadings for these outfalls will be controlled by limiting the dilution ratio consistent with the dilution ratio used to develop the concentration-based effluent limits (see also Section IV of Appendix C)
Effluent limits were not developed for Outfall 003 Rather ldquobest management practicesrdquo (BMPs) and monitoring are the permit conditions used to address storm water (see Sections VIC and VIIB of this fact sheet)
Table 2 Effluent Limitations for Outfall 001
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1 none -shy -shy 0011 0011 0092 0092
arsenic ugl 490 -shy -shy -shy ndash ndash
cadmium ugl 532 ndash 35 24 68 47
copper ugl 2452 -shy 270 180 31 21
lead ugl 5892 -shy 94 64 19 13
mercury ugl 022 -shy 046 032 0073 0050
selenium ugl -shy -shy 1505 1105 425 305
zinc ugl 1652 -shy 1500 750 210 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals are to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
10
Table 3 Effluent Limitations for Outfall 002
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1
none -shy -shy 0085 0085 018 018
arsenic ugl 490 -shy -shy -shy -shy -shy
cadmium ugl 532 ndash 11 78 52 35
copper ugl 2452 -shy 53 36 22 15
lead ugl 5892 -shy 31 21 12 83
mercury ugl 022 -shy 0077 0053 0047 0032
selenium ugl -shy -shy 235 165 175 115
zinc ugl 1652 -shy 290 200 220 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
11
Table 4 Effluent Limitations for Outfall 004
Parameter units Proposed Effluent Limitations1
at Squaw Creek flow lt 50 cfs2 at Squaw Creek flow $ 50 cfs2
Maximum Daily Monthly Average Maximum Daily Monthly Average
cadmium ugl 12 58 26 13
lbday 0084 0041 018 0091
chromium ugl 40 20 -shy -shy
lbday 028 014 -shy -shy
copper ugl 48 24 120 58
lbday 034 017 084 041
lead ugl 37 18 21 10
lbday 026 013 015 0070
mercury ugl 0037 0018 021 010
lbday 000026 000013 00015 000070
silver ugl -shy -shy 22 11
lbday -shy -shy 015 0077
zinc ugl 290 140 860 430
lbday 20 098 60 30
TSS mgl 30 20 30 20
pH su within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be total 2 - The flow tiers are representative of flow upstream of the outfall
12
Table 5 Effluent Limitations for Outfall 005
Parameter units Proposed Effluent Limitationss
Maximum Daily Monthly Average
cadmium ugl 12 62
lbday 017 0090
copper ugl 120 59
lbday 17 086
lead ugl 21 10
lbday 030 015
mercury ugl 061 030
lbday 00089 00044
silver ugl 12 60
lbday 017 0087
zinc ugl 1000 500
lbday 15 73
TSS mgl 30 20
pH su within the range of 65 - 90
Footnote 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total
VI MONITORING REQUIREMENTS
Section 308 of the Clean Water Act and federal regulation 40 CFR 12244(i) require that monitoring be included in permits to determine compliance with effluent limitations Monitoring may also be required to gather data for future effluent limitations or to monitor effluent impacts on receiving water quality TCMC is responsible for conducting the monitoring and reporting the results to EPA on monthly DMRs and in annual reports This section describes the monitoring requirements in the draft permit
A Effluent Monitoring
The effluent monitoring requirements in the draft permit are summarized in Table 6 The monitoring frequency for outfalls 001 and 002 is the same as included in the current permit (monthly for most parameters) The monitoring frequency for most of the outfall 004 and 005
13
parameters is weekly More frequent monitoring and composite sampling was determined to be necessary for these outfalls due to the composition of the outfalls (process water) the more continuous nature of the discharges and the Special Resource status of the Salmon River (Outfall 005) Flow monitoring of the receiving waters is required for outfalls 001 002 and 004 to determine which set of tiered effluent limits apply and to calculate dilution ratios (outfalls 001 and 002 only) Monitoring of Outfall 003 is discussed in Section VIC below
Some of the water quality-based effluent limits in the draft permit are close to the capability of current analytical technology to detect andor quantify (close to method detection limits) To address this concern the draft permit contains a provision requiring TCMC to use analytical methods that can achieve a method detection limit less than the effluent limitation Method detection limits are the minimum levels that can be accurately detected by current analytical technology
Table 6 Effluent Monitoring Requirements
Parameter Outfalls 001 and 002 Outfalls 004 and 005
frequency sample type frequency sample type
dilution ratio daily calculation -shy -shy
outfall flow cfs continuous recording continuous recording
metals with effluent limits1 ugl monthly grab weekly 24-hour composite
molybdenum ugl quarterly grab quarterly 24-hour composite
selenium2 ugl monthly grab quarterly 24-hour composite
TSS mgl weekly grab weekly 24-hour composite
pH standard units (su) weekly grab daily grab
hardness as CaCO3 mgl monthly grab weekly 24-hour composite
temperature oC weekly grab weekly grab
Acute WET3 TUa annually grab annually 24-hour composite
Chronic WET3 TUc annually grab quarterly 24-hour composite
Thompson Creek Flow4 cfs daily recording daily recording
Squaw Creek Flow5 cfs daily recording daily recording
Footnotes 1 - metals to be measured include cadmium chromium (outfall 004 only) copper lead mercury selenium (outfalls 001 and 002 only) silver (outfalls 004 and 005 only) and zinc 2 - selenium monitoring required for outfalls 001 and 002 (see footnote 1) and 005 3 - See Section VIB below for specific information regarding the whole effluent toxicity (WET) monitoring 4 - Thompson Creek flow monitoring is required upstream of each outfalls 001 and 002 5 - Squaw Creek flow monitoring is required upstream of Outfall 004
14
B Whole Effluent Toxicity Testing
Whole effluent toxicity (WET) is defined as the aggregate toxic effect of an effluent measured directly by an aquatic toxicity test WET tests are standardized laboratory tests that measure the total toxic effect of an effluent by exposing organisms to the effluent and noting the effects There are two different durations of toxicity tests acute and chronic Acute toxicity tests measure the test organisms survival over a 96-hour test exposure period Chronic toxicity tests measure reductions in survival growth and reproduction over a 7-day exposure
TCMC has conducted limited WET testing on their effluents In 1993 one set of WET tests were performed on effluent from outfalls 001 and 002 and some of the sources of wastewater to outfalls 004 and 005 (LA and PBS wastewaters) Results indicated no acute toxicity Chronic toxicity was indicated for Outfall 001 and the LA and PBS wastewaters at 100 effluent however the tests were not performed at dilutions representing the mixing zones In 1999 TCMC conducted an additional set of WET tests on outfalls 001 and 002 These tests indicated no acute toxicity Chronic toxicity was indicated for one species tested on Outfall 002
Federal regulations at 40 CFR 12244(d)(1) require that permits contain limits on WET when a discharge has reasonable potential to cause or contribute to an exceedence of a water quality standard In Idaho the relevant water quality standard states that surface waters of the State shall be free from toxic substances in concentrations that impair designated beneficial uses (see Appendix C Table C-2) The TSD provides guidance on implementing WET testing in NPDES permits The preliminary CWA Section 401 Certification provided by IDEQ included specific WET testing requirements for this permit (see also Section VIIIB)
Because the limited amount of existing WET testing on the TCM effluents is not adequate to determine the need for WET effluent limits WET testing has been incorporated into the draft permit The draft permit requires TCMC to conduct acute WET testing annually on effluent from each outfall Chronic WET testing must be conducted annually for outfalls 001 and 002 and quarterly for outfalls 004 and 005 TCMC is required to perform the acute tests using the salmonid species Oncorhynchus mykiss (rainbow trout) and the chronic tests using both Pimephales promelas (fathead minnow) and Ceriodaphnia dubia (water fleas) Different species are used for testing to represent different aquatic phyla (fish and invertebrates) and because different species have different sensitivities The tests will be conducted at a range of dilutions that mimic the effluent-receiving water mixing conditions Results of these tests will be used to ensure that toxics in the effluent are controlled and to determine the need for future WET limits In addition the permit establishes toxicity trigger levels for each outfall (see Appendix C Section IVB ) that if exceeded trigger additional WET testing and potentially investigations to reduce toxicity
C Storm Water Monitoring
The current permit requires TCMC to monitor the receiving water upstream and downstream of the Outfall 003 sediment ponds for turbidity The monitoring is specified as weekly during
15
February through June and monthly for the other months of the year The draft permit continues this turbidity monitoring In addition the draft permit requires daily monitoring of effluent flow and monthly monitoring of Outfall 003 for metals (cadmium copper lead mercury and zinc) hardness TSS pH and temperature to ensure that water quality standards are maintained
The storm water discharge should not adversely affect water quality This assumes appropriate design and implementation of best management practices (BMPs) in lieu of numerical effluent limits The monitoring required in the draft permit along with periodic inspections are required to evaluate the effectiveness of BMPs and to provide sufficient information to determine if these discharges either cause or contribute to water quality standards exceedences Section VIIB below discusses the BMP requirements
D Receiving Water Monitoring
The current permit requires TCMC to provide for water quality monitoring in accordance with the program agreed upon by the Interagency Task Force (members of which include the USFS BLM IDEQ EPA and TCMC) TCMCrsquos current environmental monitoring program is described in the Consolidated Environmental Monitoring Program (TCMC 1999a) This program includes monitoring of the surface water sediments and aquatic biology in the receiving waters
The draft permit requires TCMC to continue this monitoring as it relates to the permitted discharges by specifying monitoring at selected locations within and around the discharge areas The water quality monitoring requirements in the draft permit are for the most part consistent with TCMCrsquos Consolidated Monitoring Program However some additional monitoring has been added since two new outfalls are proposed (004 and 005) one of the new outfalls (005) discharges to a Special Resource Water and to verify that bioaccumulation is not of concern The following summarizes the monitoring requirements in the draft permit
Surface Water Quality Monitoring Surface water quality monitoring of the receiving waters is required four times per year upstream and downstream of each outfall for the parameters listed in Table 7 When there is a discharge from outfalls 004 or 005 the permit requires that the monitoring frequency for metals in the Salmon River be increased to monthly This was a requirement of IDEQrsquos preliminary CWA Section 401 Certification for discharge into a Special Resource Water (see also Section VIIIB) IDEQ also required that for each sampling event metals concentrations in the receiving water be compared to aquatic life chronic water quality criteria If the concentrations exceed the criteria then future sampling for that parameter will be expanded to determine 4-day average concentrations (since chronic criteria are expressed as 4shyday average concentrations)
The receiving water quality monitoring data is used to evaluate the water quality impacts of the NPDES discharges The data will also be used during the next permitting cycle to determine the need for incorporating and retaining water quality-based effluent limits into the permit In order to perform these evaluations it is necessary that the ambient monitoring use analytical methods
16
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 8: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/8.jpg)
On July 14 1994 a draft NPDES Permit for the TCM was issued for public notice The effluent limits for metals in the July 1994 draft permit were based on State of Idaho water quality criteria that were expressed as total recoverable While EPA was finalizing the permit the State of Idaho adopted new water quality criteria that express some metals as dissolved In addition a new criteria for arsenic was promulgated To accommodate these changes and the new information submitted by TCMC this new draft permit has been prepared and is being reissued for public comment
B Compliance History
TCMC submits monthly discharge monitoring reports (DMRs) to EPA summarizing the results of effluent monitoring required by the permit The following effluent limit violations were noted based on review of the past five yearsrsquo DMRs
Outfall 001 In June and July 1995 pH was reported at 91 (outside the pH limit of 6 - 9)
Outfall 002 Violations of the maximum daily effluent limits were reported in March 1999 (TSS only) May 1999 (TSS and zinc) and August 1999 (cadmium and zinc) TCMC attributed the March violation to heavy snow pack and the subsequent violations to a break in the pit diversion line located beneath the waste rock dump TCMC stopped discharging while investigating and fixing the break The diversion line has since been fixed and discharges are within the effluent limits
IV RECEIVING WATERS
As discussed in Section II the TCM outfalls discharge to Squaw Creek Thompson Creek and the Salmon River The Idaho Water Quality Standards and Wastewater Treatment Requirements designate beneficial uses for waters of the State These three waters are classified by the State of Idaho for protection of the following uses (1) agricultural water supply (2) cold water biota (3) salmonid spawning and (4) secondary contact recreation In addition the Salmon River is protected for domestic water supply and primary contact recreation and is classified as a Special Resource Water
The State water quality standards specify water quality criteria that is deemed necessary to support the use classifications These criteria may by numerical or narrative The water quality criteria applicable to the proposed permit are provided in Appendix C (Section IIIA) These criteria provide the basis for most of the effluent limits in the draft permit
Portions of Thompson Creek and the Salmon River are listed on Idahorsquos 303(d) list (a list of impaired waters compiled under Section 303(d) of the Clean Water Act) The 303(d) list identifies water bodies that do not meet or are not expected to meet water quality standards
Specifically these waters were listed as not meeting standards for
8
Thompson Creek (about three miles downstream from Outfall 002 to the confluence with the Salmon River) - sediment and metals
Salmon River (including the discharge location) - sediment and temperature
Section 303(d) of the Clean Water Act (CWA) requires States to develop a Total Maximum Daily Load (TMDL) management plan for water bodies on the 303(d) list A TMDL allocates loading capacities to point and nonpoint sources to the water body Permit limits for point sources must be consistent with applicable TMDL allocations A TMDL for Thompson Creek and this part of the Salmon River is scheduled to be completed in 2001 The General Provisions section of the draft permit contains a provision to allow EPA to reopen the permit (eg to incorporate any applicable effluent limitations and conditions which may result from final TMDLs on these receiving waters)
V EFFLUENT LIMITATIONS
EPA followed the Clean Water Act (CWA) state and federal regulations and EPArsquos 1991 Technical Support Document for Water Quality-Based Toxics Control (TSD) to develop the effluent limits in the draft permit In general the CWA requires that the effluent limit for a particular pollutant be the more stringent of either the technology-based limit or water quality-based limit Appendix C provides discussion on the legal basis for the development of technology-based and water quality-based effluent limits
EPA sets technology-based limits based on the effluent quality that is achievable using readily available technology The Agency evaluates the technology-based limits to determine whether they are adequate to ensure that water quality standards are met in the receiving water If the limits are not adequate EPA must develop additional water quality-based limits Water quality-based limits are designed to prevent exceedances of the Idaho water quality standards in the receiving waters
The proposed permit includes technology-based limits for total suspended solids (TSS) water quality-based and technology-based limits for pH and water quality-based limits for most metals Tables 2 and 3 compare the existing effluent limits for outfalls 001 and 002 with the proposed effluent limits in the draft permit Tables 4 and 5 include the proposed effluent limits for the new discharges from outfalls 004 and 005 Appendix C describes in detail how the effluent limits were developed
Two sets of limits (tiered limits) were developed for outfalls 001 002 and 004 to allow for seasonal variability of the flows in the receiving waters Except for pH and TSS the proposed effluent limits are expressed in terms of both mass (poundsday) and concentration (ugl) for outfalls 004 and 005 Establishment of mass-based limits ensures that total loadings to the receiving waters are controlled Mass limits were not calculated for outfalls 001 and 002 since the effluent flow from these outfalls is dependent upon precipitation and varies with the
9
receiving water flow Concentration-based limits for these outfalls were calculated based on the ratio of effluent flow to receiving water flow (the dilution ratio) for each flow tier Therefore mass loadings for these outfalls will be controlled by limiting the dilution ratio consistent with the dilution ratio used to develop the concentration-based effluent limits (see also Section IV of Appendix C)
Effluent limits were not developed for Outfall 003 Rather ldquobest management practicesrdquo (BMPs) and monitoring are the permit conditions used to address storm water (see Sections VIC and VIIB of this fact sheet)
Table 2 Effluent Limitations for Outfall 001
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1 none -shy -shy 0011 0011 0092 0092
arsenic ugl 490 -shy -shy -shy ndash ndash
cadmium ugl 532 ndash 35 24 68 47
copper ugl 2452 -shy 270 180 31 21
lead ugl 5892 -shy 94 64 19 13
mercury ugl 022 -shy 046 032 0073 0050
selenium ugl -shy -shy 1505 1105 425 305
zinc ugl 1652 -shy 1500 750 210 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals are to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
10
Table 3 Effluent Limitations for Outfall 002
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1
none -shy -shy 0085 0085 018 018
arsenic ugl 490 -shy -shy -shy -shy -shy
cadmium ugl 532 ndash 11 78 52 35
copper ugl 2452 -shy 53 36 22 15
lead ugl 5892 -shy 31 21 12 83
mercury ugl 022 -shy 0077 0053 0047 0032
selenium ugl -shy -shy 235 165 175 115
zinc ugl 1652 -shy 290 200 220 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
11
Table 4 Effluent Limitations for Outfall 004
Parameter units Proposed Effluent Limitations1
at Squaw Creek flow lt 50 cfs2 at Squaw Creek flow $ 50 cfs2
Maximum Daily Monthly Average Maximum Daily Monthly Average
cadmium ugl 12 58 26 13
lbday 0084 0041 018 0091
chromium ugl 40 20 -shy -shy
lbday 028 014 -shy -shy
copper ugl 48 24 120 58
lbday 034 017 084 041
lead ugl 37 18 21 10
lbday 026 013 015 0070
mercury ugl 0037 0018 021 010
lbday 000026 000013 00015 000070
silver ugl -shy -shy 22 11
lbday -shy -shy 015 0077
zinc ugl 290 140 860 430
lbday 20 098 60 30
TSS mgl 30 20 30 20
pH su within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be total 2 - The flow tiers are representative of flow upstream of the outfall
12
Table 5 Effluent Limitations for Outfall 005
Parameter units Proposed Effluent Limitationss
Maximum Daily Monthly Average
cadmium ugl 12 62
lbday 017 0090
copper ugl 120 59
lbday 17 086
lead ugl 21 10
lbday 030 015
mercury ugl 061 030
lbday 00089 00044
silver ugl 12 60
lbday 017 0087
zinc ugl 1000 500
lbday 15 73
TSS mgl 30 20
pH su within the range of 65 - 90
Footnote 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total
VI MONITORING REQUIREMENTS
Section 308 of the Clean Water Act and federal regulation 40 CFR 12244(i) require that monitoring be included in permits to determine compliance with effluent limitations Monitoring may also be required to gather data for future effluent limitations or to monitor effluent impacts on receiving water quality TCMC is responsible for conducting the monitoring and reporting the results to EPA on monthly DMRs and in annual reports This section describes the monitoring requirements in the draft permit
A Effluent Monitoring
The effluent monitoring requirements in the draft permit are summarized in Table 6 The monitoring frequency for outfalls 001 and 002 is the same as included in the current permit (monthly for most parameters) The monitoring frequency for most of the outfall 004 and 005
13
parameters is weekly More frequent monitoring and composite sampling was determined to be necessary for these outfalls due to the composition of the outfalls (process water) the more continuous nature of the discharges and the Special Resource status of the Salmon River (Outfall 005) Flow monitoring of the receiving waters is required for outfalls 001 002 and 004 to determine which set of tiered effluent limits apply and to calculate dilution ratios (outfalls 001 and 002 only) Monitoring of Outfall 003 is discussed in Section VIC below
Some of the water quality-based effluent limits in the draft permit are close to the capability of current analytical technology to detect andor quantify (close to method detection limits) To address this concern the draft permit contains a provision requiring TCMC to use analytical methods that can achieve a method detection limit less than the effluent limitation Method detection limits are the minimum levels that can be accurately detected by current analytical technology
Table 6 Effluent Monitoring Requirements
Parameter Outfalls 001 and 002 Outfalls 004 and 005
frequency sample type frequency sample type
dilution ratio daily calculation -shy -shy
outfall flow cfs continuous recording continuous recording
metals with effluent limits1 ugl monthly grab weekly 24-hour composite
molybdenum ugl quarterly grab quarterly 24-hour composite
selenium2 ugl monthly grab quarterly 24-hour composite
TSS mgl weekly grab weekly 24-hour composite
pH standard units (su) weekly grab daily grab
hardness as CaCO3 mgl monthly grab weekly 24-hour composite
temperature oC weekly grab weekly grab
Acute WET3 TUa annually grab annually 24-hour composite
Chronic WET3 TUc annually grab quarterly 24-hour composite
Thompson Creek Flow4 cfs daily recording daily recording
Squaw Creek Flow5 cfs daily recording daily recording
Footnotes 1 - metals to be measured include cadmium chromium (outfall 004 only) copper lead mercury selenium (outfalls 001 and 002 only) silver (outfalls 004 and 005 only) and zinc 2 - selenium monitoring required for outfalls 001 and 002 (see footnote 1) and 005 3 - See Section VIB below for specific information regarding the whole effluent toxicity (WET) monitoring 4 - Thompson Creek flow monitoring is required upstream of each outfalls 001 and 002 5 - Squaw Creek flow monitoring is required upstream of Outfall 004
14
B Whole Effluent Toxicity Testing
Whole effluent toxicity (WET) is defined as the aggregate toxic effect of an effluent measured directly by an aquatic toxicity test WET tests are standardized laboratory tests that measure the total toxic effect of an effluent by exposing organisms to the effluent and noting the effects There are two different durations of toxicity tests acute and chronic Acute toxicity tests measure the test organisms survival over a 96-hour test exposure period Chronic toxicity tests measure reductions in survival growth and reproduction over a 7-day exposure
TCMC has conducted limited WET testing on their effluents In 1993 one set of WET tests were performed on effluent from outfalls 001 and 002 and some of the sources of wastewater to outfalls 004 and 005 (LA and PBS wastewaters) Results indicated no acute toxicity Chronic toxicity was indicated for Outfall 001 and the LA and PBS wastewaters at 100 effluent however the tests were not performed at dilutions representing the mixing zones In 1999 TCMC conducted an additional set of WET tests on outfalls 001 and 002 These tests indicated no acute toxicity Chronic toxicity was indicated for one species tested on Outfall 002
Federal regulations at 40 CFR 12244(d)(1) require that permits contain limits on WET when a discharge has reasonable potential to cause or contribute to an exceedence of a water quality standard In Idaho the relevant water quality standard states that surface waters of the State shall be free from toxic substances in concentrations that impair designated beneficial uses (see Appendix C Table C-2) The TSD provides guidance on implementing WET testing in NPDES permits The preliminary CWA Section 401 Certification provided by IDEQ included specific WET testing requirements for this permit (see also Section VIIIB)
Because the limited amount of existing WET testing on the TCM effluents is not adequate to determine the need for WET effluent limits WET testing has been incorporated into the draft permit The draft permit requires TCMC to conduct acute WET testing annually on effluent from each outfall Chronic WET testing must be conducted annually for outfalls 001 and 002 and quarterly for outfalls 004 and 005 TCMC is required to perform the acute tests using the salmonid species Oncorhynchus mykiss (rainbow trout) and the chronic tests using both Pimephales promelas (fathead minnow) and Ceriodaphnia dubia (water fleas) Different species are used for testing to represent different aquatic phyla (fish and invertebrates) and because different species have different sensitivities The tests will be conducted at a range of dilutions that mimic the effluent-receiving water mixing conditions Results of these tests will be used to ensure that toxics in the effluent are controlled and to determine the need for future WET limits In addition the permit establishes toxicity trigger levels for each outfall (see Appendix C Section IVB ) that if exceeded trigger additional WET testing and potentially investigations to reduce toxicity
C Storm Water Monitoring
The current permit requires TCMC to monitor the receiving water upstream and downstream of the Outfall 003 sediment ponds for turbidity The monitoring is specified as weekly during
15
February through June and monthly for the other months of the year The draft permit continues this turbidity monitoring In addition the draft permit requires daily monitoring of effluent flow and monthly monitoring of Outfall 003 for metals (cadmium copper lead mercury and zinc) hardness TSS pH and temperature to ensure that water quality standards are maintained
The storm water discharge should not adversely affect water quality This assumes appropriate design and implementation of best management practices (BMPs) in lieu of numerical effluent limits The monitoring required in the draft permit along with periodic inspections are required to evaluate the effectiveness of BMPs and to provide sufficient information to determine if these discharges either cause or contribute to water quality standards exceedences Section VIIB below discusses the BMP requirements
D Receiving Water Monitoring
The current permit requires TCMC to provide for water quality monitoring in accordance with the program agreed upon by the Interagency Task Force (members of which include the USFS BLM IDEQ EPA and TCMC) TCMCrsquos current environmental monitoring program is described in the Consolidated Environmental Monitoring Program (TCMC 1999a) This program includes monitoring of the surface water sediments and aquatic biology in the receiving waters
The draft permit requires TCMC to continue this monitoring as it relates to the permitted discharges by specifying monitoring at selected locations within and around the discharge areas The water quality monitoring requirements in the draft permit are for the most part consistent with TCMCrsquos Consolidated Monitoring Program However some additional monitoring has been added since two new outfalls are proposed (004 and 005) one of the new outfalls (005) discharges to a Special Resource Water and to verify that bioaccumulation is not of concern The following summarizes the monitoring requirements in the draft permit
Surface Water Quality Monitoring Surface water quality monitoring of the receiving waters is required four times per year upstream and downstream of each outfall for the parameters listed in Table 7 When there is a discharge from outfalls 004 or 005 the permit requires that the monitoring frequency for metals in the Salmon River be increased to monthly This was a requirement of IDEQrsquos preliminary CWA Section 401 Certification for discharge into a Special Resource Water (see also Section VIIIB) IDEQ also required that for each sampling event metals concentrations in the receiving water be compared to aquatic life chronic water quality criteria If the concentrations exceed the criteria then future sampling for that parameter will be expanded to determine 4-day average concentrations (since chronic criteria are expressed as 4shyday average concentrations)
The receiving water quality monitoring data is used to evaluate the water quality impacts of the NPDES discharges The data will also be used during the next permitting cycle to determine the need for incorporating and retaining water quality-based effluent limits into the permit In order to perform these evaluations it is necessary that the ambient monitoring use analytical methods
16
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 9: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/9.jpg)
Thompson Creek (about three miles downstream from Outfall 002 to the confluence with the Salmon River) - sediment and metals
Salmon River (including the discharge location) - sediment and temperature
Section 303(d) of the Clean Water Act (CWA) requires States to develop a Total Maximum Daily Load (TMDL) management plan for water bodies on the 303(d) list A TMDL allocates loading capacities to point and nonpoint sources to the water body Permit limits for point sources must be consistent with applicable TMDL allocations A TMDL for Thompson Creek and this part of the Salmon River is scheduled to be completed in 2001 The General Provisions section of the draft permit contains a provision to allow EPA to reopen the permit (eg to incorporate any applicable effluent limitations and conditions which may result from final TMDLs on these receiving waters)
V EFFLUENT LIMITATIONS
EPA followed the Clean Water Act (CWA) state and federal regulations and EPArsquos 1991 Technical Support Document for Water Quality-Based Toxics Control (TSD) to develop the effluent limits in the draft permit In general the CWA requires that the effluent limit for a particular pollutant be the more stringent of either the technology-based limit or water quality-based limit Appendix C provides discussion on the legal basis for the development of technology-based and water quality-based effluent limits
EPA sets technology-based limits based on the effluent quality that is achievable using readily available technology The Agency evaluates the technology-based limits to determine whether they are adequate to ensure that water quality standards are met in the receiving water If the limits are not adequate EPA must develop additional water quality-based limits Water quality-based limits are designed to prevent exceedances of the Idaho water quality standards in the receiving waters
The proposed permit includes technology-based limits for total suspended solids (TSS) water quality-based and technology-based limits for pH and water quality-based limits for most metals Tables 2 and 3 compare the existing effluent limits for outfalls 001 and 002 with the proposed effluent limits in the draft permit Tables 4 and 5 include the proposed effluent limits for the new discharges from outfalls 004 and 005 Appendix C describes in detail how the effluent limits were developed
Two sets of limits (tiered limits) were developed for outfalls 001 002 and 004 to allow for seasonal variability of the flows in the receiving waters Except for pH and TSS the proposed effluent limits are expressed in terms of both mass (poundsday) and concentration (ugl) for outfalls 004 and 005 Establishment of mass-based limits ensures that total loadings to the receiving waters are controlled Mass limits were not calculated for outfalls 001 and 002 since the effluent flow from these outfalls is dependent upon precipitation and varies with the
9
receiving water flow Concentration-based limits for these outfalls were calculated based on the ratio of effluent flow to receiving water flow (the dilution ratio) for each flow tier Therefore mass loadings for these outfalls will be controlled by limiting the dilution ratio consistent with the dilution ratio used to develop the concentration-based effluent limits (see also Section IV of Appendix C)
Effluent limits were not developed for Outfall 003 Rather ldquobest management practicesrdquo (BMPs) and monitoring are the permit conditions used to address storm water (see Sections VIC and VIIB of this fact sheet)
Table 2 Effluent Limitations for Outfall 001
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1 none -shy -shy 0011 0011 0092 0092
arsenic ugl 490 -shy -shy -shy ndash ndash
cadmium ugl 532 ndash 35 24 68 47
copper ugl 2452 -shy 270 180 31 21
lead ugl 5892 -shy 94 64 19 13
mercury ugl 022 -shy 046 032 0073 0050
selenium ugl -shy -shy 1505 1105 425 305
zinc ugl 1652 -shy 1500 750 210 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals are to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
10
Table 3 Effluent Limitations for Outfall 002
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1
none -shy -shy 0085 0085 018 018
arsenic ugl 490 -shy -shy -shy -shy -shy
cadmium ugl 532 ndash 11 78 52 35
copper ugl 2452 -shy 53 36 22 15
lead ugl 5892 -shy 31 21 12 83
mercury ugl 022 -shy 0077 0053 0047 0032
selenium ugl -shy -shy 235 165 175 115
zinc ugl 1652 -shy 290 200 220 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
11
Table 4 Effluent Limitations for Outfall 004
Parameter units Proposed Effluent Limitations1
at Squaw Creek flow lt 50 cfs2 at Squaw Creek flow $ 50 cfs2
Maximum Daily Monthly Average Maximum Daily Monthly Average
cadmium ugl 12 58 26 13
lbday 0084 0041 018 0091
chromium ugl 40 20 -shy -shy
lbday 028 014 -shy -shy
copper ugl 48 24 120 58
lbday 034 017 084 041
lead ugl 37 18 21 10
lbday 026 013 015 0070
mercury ugl 0037 0018 021 010
lbday 000026 000013 00015 000070
silver ugl -shy -shy 22 11
lbday -shy -shy 015 0077
zinc ugl 290 140 860 430
lbday 20 098 60 30
TSS mgl 30 20 30 20
pH su within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be total 2 - The flow tiers are representative of flow upstream of the outfall
12
Table 5 Effluent Limitations for Outfall 005
Parameter units Proposed Effluent Limitationss
Maximum Daily Monthly Average
cadmium ugl 12 62
lbday 017 0090
copper ugl 120 59
lbday 17 086
lead ugl 21 10
lbday 030 015
mercury ugl 061 030
lbday 00089 00044
silver ugl 12 60
lbday 017 0087
zinc ugl 1000 500
lbday 15 73
TSS mgl 30 20
pH su within the range of 65 - 90
Footnote 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total
VI MONITORING REQUIREMENTS
Section 308 of the Clean Water Act and federal regulation 40 CFR 12244(i) require that monitoring be included in permits to determine compliance with effluent limitations Monitoring may also be required to gather data for future effluent limitations or to monitor effluent impacts on receiving water quality TCMC is responsible for conducting the monitoring and reporting the results to EPA on monthly DMRs and in annual reports This section describes the monitoring requirements in the draft permit
A Effluent Monitoring
The effluent monitoring requirements in the draft permit are summarized in Table 6 The monitoring frequency for outfalls 001 and 002 is the same as included in the current permit (monthly for most parameters) The monitoring frequency for most of the outfall 004 and 005
13
parameters is weekly More frequent monitoring and composite sampling was determined to be necessary for these outfalls due to the composition of the outfalls (process water) the more continuous nature of the discharges and the Special Resource status of the Salmon River (Outfall 005) Flow monitoring of the receiving waters is required for outfalls 001 002 and 004 to determine which set of tiered effluent limits apply and to calculate dilution ratios (outfalls 001 and 002 only) Monitoring of Outfall 003 is discussed in Section VIC below
Some of the water quality-based effluent limits in the draft permit are close to the capability of current analytical technology to detect andor quantify (close to method detection limits) To address this concern the draft permit contains a provision requiring TCMC to use analytical methods that can achieve a method detection limit less than the effluent limitation Method detection limits are the minimum levels that can be accurately detected by current analytical technology
Table 6 Effluent Monitoring Requirements
Parameter Outfalls 001 and 002 Outfalls 004 and 005
frequency sample type frequency sample type
dilution ratio daily calculation -shy -shy
outfall flow cfs continuous recording continuous recording
metals with effluent limits1 ugl monthly grab weekly 24-hour composite
molybdenum ugl quarterly grab quarterly 24-hour composite
selenium2 ugl monthly grab quarterly 24-hour composite
TSS mgl weekly grab weekly 24-hour composite
pH standard units (su) weekly grab daily grab
hardness as CaCO3 mgl monthly grab weekly 24-hour composite
temperature oC weekly grab weekly grab
Acute WET3 TUa annually grab annually 24-hour composite
Chronic WET3 TUc annually grab quarterly 24-hour composite
Thompson Creek Flow4 cfs daily recording daily recording
Squaw Creek Flow5 cfs daily recording daily recording
Footnotes 1 - metals to be measured include cadmium chromium (outfall 004 only) copper lead mercury selenium (outfalls 001 and 002 only) silver (outfalls 004 and 005 only) and zinc 2 - selenium monitoring required for outfalls 001 and 002 (see footnote 1) and 005 3 - See Section VIB below for specific information regarding the whole effluent toxicity (WET) monitoring 4 - Thompson Creek flow monitoring is required upstream of each outfalls 001 and 002 5 - Squaw Creek flow monitoring is required upstream of Outfall 004
14
B Whole Effluent Toxicity Testing
Whole effluent toxicity (WET) is defined as the aggregate toxic effect of an effluent measured directly by an aquatic toxicity test WET tests are standardized laboratory tests that measure the total toxic effect of an effluent by exposing organisms to the effluent and noting the effects There are two different durations of toxicity tests acute and chronic Acute toxicity tests measure the test organisms survival over a 96-hour test exposure period Chronic toxicity tests measure reductions in survival growth and reproduction over a 7-day exposure
TCMC has conducted limited WET testing on their effluents In 1993 one set of WET tests were performed on effluent from outfalls 001 and 002 and some of the sources of wastewater to outfalls 004 and 005 (LA and PBS wastewaters) Results indicated no acute toxicity Chronic toxicity was indicated for Outfall 001 and the LA and PBS wastewaters at 100 effluent however the tests were not performed at dilutions representing the mixing zones In 1999 TCMC conducted an additional set of WET tests on outfalls 001 and 002 These tests indicated no acute toxicity Chronic toxicity was indicated for one species tested on Outfall 002
Federal regulations at 40 CFR 12244(d)(1) require that permits contain limits on WET when a discharge has reasonable potential to cause or contribute to an exceedence of a water quality standard In Idaho the relevant water quality standard states that surface waters of the State shall be free from toxic substances in concentrations that impair designated beneficial uses (see Appendix C Table C-2) The TSD provides guidance on implementing WET testing in NPDES permits The preliminary CWA Section 401 Certification provided by IDEQ included specific WET testing requirements for this permit (see also Section VIIIB)
Because the limited amount of existing WET testing on the TCM effluents is not adequate to determine the need for WET effluent limits WET testing has been incorporated into the draft permit The draft permit requires TCMC to conduct acute WET testing annually on effluent from each outfall Chronic WET testing must be conducted annually for outfalls 001 and 002 and quarterly for outfalls 004 and 005 TCMC is required to perform the acute tests using the salmonid species Oncorhynchus mykiss (rainbow trout) and the chronic tests using both Pimephales promelas (fathead minnow) and Ceriodaphnia dubia (water fleas) Different species are used for testing to represent different aquatic phyla (fish and invertebrates) and because different species have different sensitivities The tests will be conducted at a range of dilutions that mimic the effluent-receiving water mixing conditions Results of these tests will be used to ensure that toxics in the effluent are controlled and to determine the need for future WET limits In addition the permit establishes toxicity trigger levels for each outfall (see Appendix C Section IVB ) that if exceeded trigger additional WET testing and potentially investigations to reduce toxicity
C Storm Water Monitoring
The current permit requires TCMC to monitor the receiving water upstream and downstream of the Outfall 003 sediment ponds for turbidity The monitoring is specified as weekly during
15
February through June and monthly for the other months of the year The draft permit continues this turbidity monitoring In addition the draft permit requires daily monitoring of effluent flow and monthly monitoring of Outfall 003 for metals (cadmium copper lead mercury and zinc) hardness TSS pH and temperature to ensure that water quality standards are maintained
The storm water discharge should not adversely affect water quality This assumes appropriate design and implementation of best management practices (BMPs) in lieu of numerical effluent limits The monitoring required in the draft permit along with periodic inspections are required to evaluate the effectiveness of BMPs and to provide sufficient information to determine if these discharges either cause or contribute to water quality standards exceedences Section VIIB below discusses the BMP requirements
D Receiving Water Monitoring
The current permit requires TCMC to provide for water quality monitoring in accordance with the program agreed upon by the Interagency Task Force (members of which include the USFS BLM IDEQ EPA and TCMC) TCMCrsquos current environmental monitoring program is described in the Consolidated Environmental Monitoring Program (TCMC 1999a) This program includes monitoring of the surface water sediments and aquatic biology in the receiving waters
The draft permit requires TCMC to continue this monitoring as it relates to the permitted discharges by specifying monitoring at selected locations within and around the discharge areas The water quality monitoring requirements in the draft permit are for the most part consistent with TCMCrsquos Consolidated Monitoring Program However some additional monitoring has been added since two new outfalls are proposed (004 and 005) one of the new outfalls (005) discharges to a Special Resource Water and to verify that bioaccumulation is not of concern The following summarizes the monitoring requirements in the draft permit
Surface Water Quality Monitoring Surface water quality monitoring of the receiving waters is required four times per year upstream and downstream of each outfall for the parameters listed in Table 7 When there is a discharge from outfalls 004 or 005 the permit requires that the monitoring frequency for metals in the Salmon River be increased to monthly This was a requirement of IDEQrsquos preliminary CWA Section 401 Certification for discharge into a Special Resource Water (see also Section VIIIB) IDEQ also required that for each sampling event metals concentrations in the receiving water be compared to aquatic life chronic water quality criteria If the concentrations exceed the criteria then future sampling for that parameter will be expanded to determine 4-day average concentrations (since chronic criteria are expressed as 4shyday average concentrations)
The receiving water quality monitoring data is used to evaluate the water quality impacts of the NPDES discharges The data will also be used during the next permitting cycle to determine the need for incorporating and retaining water quality-based effluent limits into the permit In order to perform these evaluations it is necessary that the ambient monitoring use analytical methods
16
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 10: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/10.jpg)
receiving water flow Concentration-based limits for these outfalls were calculated based on the ratio of effluent flow to receiving water flow (the dilution ratio) for each flow tier Therefore mass loadings for these outfalls will be controlled by limiting the dilution ratio consistent with the dilution ratio used to develop the concentration-based effluent limits (see also Section IV of Appendix C)
Effluent limits were not developed for Outfall 003 Rather ldquobest management practicesrdquo (BMPs) and monitoring are the permit conditions used to address storm water (see Sections VIC and VIIB of this fact sheet)
Table 2 Effluent Limitations for Outfall 001
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1 none -shy -shy 0011 0011 0092 0092
arsenic ugl 490 -shy -shy -shy ndash ndash
cadmium ugl 532 ndash 35 24 68 47
copper ugl 2452 -shy 270 180 31 21
lead ugl 5892 -shy 94 64 19 13
mercury ugl 022 -shy 046 032 0073 0050
selenium ugl -shy -shy 1505 1105 425 305
zinc ugl 1652 -shy 1500 750 210 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals are to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
10
Table 3 Effluent Limitations for Outfall 002
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1
none -shy -shy 0085 0085 018 018
arsenic ugl 490 -shy -shy -shy -shy -shy
cadmium ugl 532 ndash 11 78 52 35
copper ugl 2452 -shy 53 36 22 15
lead ugl 5892 -shy 31 21 12 83
mercury ugl 022 -shy 0077 0053 0047 0032
selenium ugl -shy -shy 235 165 175 115
zinc ugl 1652 -shy 290 200 220 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
11
Table 4 Effluent Limitations for Outfall 004
Parameter units Proposed Effluent Limitations1
at Squaw Creek flow lt 50 cfs2 at Squaw Creek flow $ 50 cfs2
Maximum Daily Monthly Average Maximum Daily Monthly Average
cadmium ugl 12 58 26 13
lbday 0084 0041 018 0091
chromium ugl 40 20 -shy -shy
lbday 028 014 -shy -shy
copper ugl 48 24 120 58
lbday 034 017 084 041
lead ugl 37 18 21 10
lbday 026 013 015 0070
mercury ugl 0037 0018 021 010
lbday 000026 000013 00015 000070
silver ugl -shy -shy 22 11
lbday -shy -shy 015 0077
zinc ugl 290 140 860 430
lbday 20 098 60 30
TSS mgl 30 20 30 20
pH su within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be total 2 - The flow tiers are representative of flow upstream of the outfall
12
Table 5 Effluent Limitations for Outfall 005
Parameter units Proposed Effluent Limitationss
Maximum Daily Monthly Average
cadmium ugl 12 62
lbday 017 0090
copper ugl 120 59
lbday 17 086
lead ugl 21 10
lbday 030 015
mercury ugl 061 030
lbday 00089 00044
silver ugl 12 60
lbday 017 0087
zinc ugl 1000 500
lbday 15 73
TSS mgl 30 20
pH su within the range of 65 - 90
Footnote 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total
VI MONITORING REQUIREMENTS
Section 308 of the Clean Water Act and federal regulation 40 CFR 12244(i) require that monitoring be included in permits to determine compliance with effluent limitations Monitoring may also be required to gather data for future effluent limitations or to monitor effluent impacts on receiving water quality TCMC is responsible for conducting the monitoring and reporting the results to EPA on monthly DMRs and in annual reports This section describes the monitoring requirements in the draft permit
A Effluent Monitoring
The effluent monitoring requirements in the draft permit are summarized in Table 6 The monitoring frequency for outfalls 001 and 002 is the same as included in the current permit (monthly for most parameters) The monitoring frequency for most of the outfall 004 and 005
13
parameters is weekly More frequent monitoring and composite sampling was determined to be necessary for these outfalls due to the composition of the outfalls (process water) the more continuous nature of the discharges and the Special Resource status of the Salmon River (Outfall 005) Flow monitoring of the receiving waters is required for outfalls 001 002 and 004 to determine which set of tiered effluent limits apply and to calculate dilution ratios (outfalls 001 and 002 only) Monitoring of Outfall 003 is discussed in Section VIC below
Some of the water quality-based effluent limits in the draft permit are close to the capability of current analytical technology to detect andor quantify (close to method detection limits) To address this concern the draft permit contains a provision requiring TCMC to use analytical methods that can achieve a method detection limit less than the effluent limitation Method detection limits are the minimum levels that can be accurately detected by current analytical technology
Table 6 Effluent Monitoring Requirements
Parameter Outfalls 001 and 002 Outfalls 004 and 005
frequency sample type frequency sample type
dilution ratio daily calculation -shy -shy
outfall flow cfs continuous recording continuous recording
metals with effluent limits1 ugl monthly grab weekly 24-hour composite
molybdenum ugl quarterly grab quarterly 24-hour composite
selenium2 ugl monthly grab quarterly 24-hour composite
TSS mgl weekly grab weekly 24-hour composite
pH standard units (su) weekly grab daily grab
hardness as CaCO3 mgl monthly grab weekly 24-hour composite
temperature oC weekly grab weekly grab
Acute WET3 TUa annually grab annually 24-hour composite
Chronic WET3 TUc annually grab quarterly 24-hour composite
Thompson Creek Flow4 cfs daily recording daily recording
Squaw Creek Flow5 cfs daily recording daily recording
Footnotes 1 - metals to be measured include cadmium chromium (outfall 004 only) copper lead mercury selenium (outfalls 001 and 002 only) silver (outfalls 004 and 005 only) and zinc 2 - selenium monitoring required for outfalls 001 and 002 (see footnote 1) and 005 3 - See Section VIB below for specific information regarding the whole effluent toxicity (WET) monitoring 4 - Thompson Creek flow monitoring is required upstream of each outfalls 001 and 002 5 - Squaw Creek flow monitoring is required upstream of Outfall 004
14
B Whole Effluent Toxicity Testing
Whole effluent toxicity (WET) is defined as the aggregate toxic effect of an effluent measured directly by an aquatic toxicity test WET tests are standardized laboratory tests that measure the total toxic effect of an effluent by exposing organisms to the effluent and noting the effects There are two different durations of toxicity tests acute and chronic Acute toxicity tests measure the test organisms survival over a 96-hour test exposure period Chronic toxicity tests measure reductions in survival growth and reproduction over a 7-day exposure
TCMC has conducted limited WET testing on their effluents In 1993 one set of WET tests were performed on effluent from outfalls 001 and 002 and some of the sources of wastewater to outfalls 004 and 005 (LA and PBS wastewaters) Results indicated no acute toxicity Chronic toxicity was indicated for Outfall 001 and the LA and PBS wastewaters at 100 effluent however the tests were not performed at dilutions representing the mixing zones In 1999 TCMC conducted an additional set of WET tests on outfalls 001 and 002 These tests indicated no acute toxicity Chronic toxicity was indicated for one species tested on Outfall 002
Federal regulations at 40 CFR 12244(d)(1) require that permits contain limits on WET when a discharge has reasonable potential to cause or contribute to an exceedence of a water quality standard In Idaho the relevant water quality standard states that surface waters of the State shall be free from toxic substances in concentrations that impair designated beneficial uses (see Appendix C Table C-2) The TSD provides guidance on implementing WET testing in NPDES permits The preliminary CWA Section 401 Certification provided by IDEQ included specific WET testing requirements for this permit (see also Section VIIIB)
Because the limited amount of existing WET testing on the TCM effluents is not adequate to determine the need for WET effluent limits WET testing has been incorporated into the draft permit The draft permit requires TCMC to conduct acute WET testing annually on effluent from each outfall Chronic WET testing must be conducted annually for outfalls 001 and 002 and quarterly for outfalls 004 and 005 TCMC is required to perform the acute tests using the salmonid species Oncorhynchus mykiss (rainbow trout) and the chronic tests using both Pimephales promelas (fathead minnow) and Ceriodaphnia dubia (water fleas) Different species are used for testing to represent different aquatic phyla (fish and invertebrates) and because different species have different sensitivities The tests will be conducted at a range of dilutions that mimic the effluent-receiving water mixing conditions Results of these tests will be used to ensure that toxics in the effluent are controlled and to determine the need for future WET limits In addition the permit establishes toxicity trigger levels for each outfall (see Appendix C Section IVB ) that if exceeded trigger additional WET testing and potentially investigations to reduce toxicity
C Storm Water Monitoring
The current permit requires TCMC to monitor the receiving water upstream and downstream of the Outfall 003 sediment ponds for turbidity The monitoring is specified as weekly during
15
February through June and monthly for the other months of the year The draft permit continues this turbidity monitoring In addition the draft permit requires daily monitoring of effluent flow and monthly monitoring of Outfall 003 for metals (cadmium copper lead mercury and zinc) hardness TSS pH and temperature to ensure that water quality standards are maintained
The storm water discharge should not adversely affect water quality This assumes appropriate design and implementation of best management practices (BMPs) in lieu of numerical effluent limits The monitoring required in the draft permit along with periodic inspections are required to evaluate the effectiveness of BMPs and to provide sufficient information to determine if these discharges either cause or contribute to water quality standards exceedences Section VIIB below discusses the BMP requirements
D Receiving Water Monitoring
The current permit requires TCMC to provide for water quality monitoring in accordance with the program agreed upon by the Interagency Task Force (members of which include the USFS BLM IDEQ EPA and TCMC) TCMCrsquos current environmental monitoring program is described in the Consolidated Environmental Monitoring Program (TCMC 1999a) This program includes monitoring of the surface water sediments and aquatic biology in the receiving waters
The draft permit requires TCMC to continue this monitoring as it relates to the permitted discharges by specifying monitoring at selected locations within and around the discharge areas The water quality monitoring requirements in the draft permit are for the most part consistent with TCMCrsquos Consolidated Monitoring Program However some additional monitoring has been added since two new outfalls are proposed (004 and 005) one of the new outfalls (005) discharges to a Special Resource Water and to verify that bioaccumulation is not of concern The following summarizes the monitoring requirements in the draft permit
Surface Water Quality Monitoring Surface water quality monitoring of the receiving waters is required four times per year upstream and downstream of each outfall for the parameters listed in Table 7 When there is a discharge from outfalls 004 or 005 the permit requires that the monitoring frequency for metals in the Salmon River be increased to monthly This was a requirement of IDEQrsquos preliminary CWA Section 401 Certification for discharge into a Special Resource Water (see also Section VIIIB) IDEQ also required that for each sampling event metals concentrations in the receiving water be compared to aquatic life chronic water quality criteria If the concentrations exceed the criteria then future sampling for that parameter will be expanded to determine 4-day average concentrations (since chronic criteria are expressed as 4shyday average concentrations)
The receiving water quality monitoring data is used to evaluate the water quality impacts of the NPDES discharges The data will also be used during the next permitting cycle to determine the need for incorporating and retaining water quality-based effluent limits into the permit In order to perform these evaluations it is necessary that the ambient monitoring use analytical methods
16
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 11: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/11.jpg)
Table 3 Effluent Limitations for Outfall 002
Parameter units Existing Effluent Limitations
Proposed Effluent Limitations3
at Thompson Creek flow lt 7 cfs4
at Thompson Creek flow $ 7 cfs4
Maximu m Daily
Monthly Average
Maximum Daily
Monthly Average
Maximum Daily
Monthly Average
dilution ratio1
none -shy -shy 0085 0085 018 018
arsenic ugl 490 -shy -shy -shy -shy -shy
cadmium ugl 532 ndash 11 78 52 35
copper ugl 2452 -shy 53 36 22 15
lead ugl 5892 -shy 31 21 12 83
mercury ugl 022 -shy 0077 0053 0047 0032
selenium ugl -shy -shy 235 165 175 115
zinc ugl 1652 -shy 290 200 220 150
TSS mgl 30 20 30 20 30 20
pH su within the range of 6 - 9 within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - The dilution ratio is calculated by dividing the effluent flow by the flow in Thompson Creek upstream of the discharge 2 - Alternate effluent limits were established based on background or the maximum daily technology-based effluent guidelines (see Appendix C Table C-1) whichever is more stringent 3 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total 4 - The flow tiers are representative of flow upstream of the outfall 5 - Compliance with the selenium limits must be achieved within 4 years and 11 months of the effective date of the permit (see Section VIIIB of the fact sheet)
11
Table 4 Effluent Limitations for Outfall 004
Parameter units Proposed Effluent Limitations1
at Squaw Creek flow lt 50 cfs2 at Squaw Creek flow $ 50 cfs2
Maximum Daily Monthly Average Maximum Daily Monthly Average
cadmium ugl 12 58 26 13
lbday 0084 0041 018 0091
chromium ugl 40 20 -shy -shy
lbday 028 014 -shy -shy
copper ugl 48 24 120 58
lbday 034 017 084 041
lead ugl 37 18 21 10
lbday 026 013 015 0070
mercury ugl 0037 0018 021 010
lbday 000026 000013 00015 000070
silver ugl -shy -shy 22 11
lbday -shy -shy 015 0077
zinc ugl 290 140 860 430
lbday 20 098 60 30
TSS mgl 30 20 30 20
pH su within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be total 2 - The flow tiers are representative of flow upstream of the outfall
12
Table 5 Effluent Limitations for Outfall 005
Parameter units Proposed Effluent Limitationss
Maximum Daily Monthly Average
cadmium ugl 12 62
lbday 017 0090
copper ugl 120 59
lbday 17 086
lead ugl 21 10
lbday 030 015
mercury ugl 061 030
lbday 00089 00044
silver ugl 12 60
lbday 017 0087
zinc ugl 1000 500
lbday 15 73
TSS mgl 30 20
pH su within the range of 65 - 90
Footnote 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total
VI MONITORING REQUIREMENTS
Section 308 of the Clean Water Act and federal regulation 40 CFR 12244(i) require that monitoring be included in permits to determine compliance with effluent limitations Monitoring may also be required to gather data for future effluent limitations or to monitor effluent impacts on receiving water quality TCMC is responsible for conducting the monitoring and reporting the results to EPA on monthly DMRs and in annual reports This section describes the monitoring requirements in the draft permit
A Effluent Monitoring
The effluent monitoring requirements in the draft permit are summarized in Table 6 The monitoring frequency for outfalls 001 and 002 is the same as included in the current permit (monthly for most parameters) The monitoring frequency for most of the outfall 004 and 005
13
parameters is weekly More frequent monitoring and composite sampling was determined to be necessary for these outfalls due to the composition of the outfalls (process water) the more continuous nature of the discharges and the Special Resource status of the Salmon River (Outfall 005) Flow monitoring of the receiving waters is required for outfalls 001 002 and 004 to determine which set of tiered effluent limits apply and to calculate dilution ratios (outfalls 001 and 002 only) Monitoring of Outfall 003 is discussed in Section VIC below
Some of the water quality-based effluent limits in the draft permit are close to the capability of current analytical technology to detect andor quantify (close to method detection limits) To address this concern the draft permit contains a provision requiring TCMC to use analytical methods that can achieve a method detection limit less than the effluent limitation Method detection limits are the minimum levels that can be accurately detected by current analytical technology
Table 6 Effluent Monitoring Requirements
Parameter Outfalls 001 and 002 Outfalls 004 and 005
frequency sample type frequency sample type
dilution ratio daily calculation -shy -shy
outfall flow cfs continuous recording continuous recording
metals with effluent limits1 ugl monthly grab weekly 24-hour composite
molybdenum ugl quarterly grab quarterly 24-hour composite
selenium2 ugl monthly grab quarterly 24-hour composite
TSS mgl weekly grab weekly 24-hour composite
pH standard units (su) weekly grab daily grab
hardness as CaCO3 mgl monthly grab weekly 24-hour composite
temperature oC weekly grab weekly grab
Acute WET3 TUa annually grab annually 24-hour composite
Chronic WET3 TUc annually grab quarterly 24-hour composite
Thompson Creek Flow4 cfs daily recording daily recording
Squaw Creek Flow5 cfs daily recording daily recording
Footnotes 1 - metals to be measured include cadmium chromium (outfall 004 only) copper lead mercury selenium (outfalls 001 and 002 only) silver (outfalls 004 and 005 only) and zinc 2 - selenium monitoring required for outfalls 001 and 002 (see footnote 1) and 005 3 - See Section VIB below for specific information regarding the whole effluent toxicity (WET) monitoring 4 - Thompson Creek flow monitoring is required upstream of each outfalls 001 and 002 5 - Squaw Creek flow monitoring is required upstream of Outfall 004
14
B Whole Effluent Toxicity Testing
Whole effluent toxicity (WET) is defined as the aggregate toxic effect of an effluent measured directly by an aquatic toxicity test WET tests are standardized laboratory tests that measure the total toxic effect of an effluent by exposing organisms to the effluent and noting the effects There are two different durations of toxicity tests acute and chronic Acute toxicity tests measure the test organisms survival over a 96-hour test exposure period Chronic toxicity tests measure reductions in survival growth and reproduction over a 7-day exposure
TCMC has conducted limited WET testing on their effluents In 1993 one set of WET tests were performed on effluent from outfalls 001 and 002 and some of the sources of wastewater to outfalls 004 and 005 (LA and PBS wastewaters) Results indicated no acute toxicity Chronic toxicity was indicated for Outfall 001 and the LA and PBS wastewaters at 100 effluent however the tests were not performed at dilutions representing the mixing zones In 1999 TCMC conducted an additional set of WET tests on outfalls 001 and 002 These tests indicated no acute toxicity Chronic toxicity was indicated for one species tested on Outfall 002
Federal regulations at 40 CFR 12244(d)(1) require that permits contain limits on WET when a discharge has reasonable potential to cause or contribute to an exceedence of a water quality standard In Idaho the relevant water quality standard states that surface waters of the State shall be free from toxic substances in concentrations that impair designated beneficial uses (see Appendix C Table C-2) The TSD provides guidance on implementing WET testing in NPDES permits The preliminary CWA Section 401 Certification provided by IDEQ included specific WET testing requirements for this permit (see also Section VIIIB)
Because the limited amount of existing WET testing on the TCM effluents is not adequate to determine the need for WET effluent limits WET testing has been incorporated into the draft permit The draft permit requires TCMC to conduct acute WET testing annually on effluent from each outfall Chronic WET testing must be conducted annually for outfalls 001 and 002 and quarterly for outfalls 004 and 005 TCMC is required to perform the acute tests using the salmonid species Oncorhynchus mykiss (rainbow trout) and the chronic tests using both Pimephales promelas (fathead minnow) and Ceriodaphnia dubia (water fleas) Different species are used for testing to represent different aquatic phyla (fish and invertebrates) and because different species have different sensitivities The tests will be conducted at a range of dilutions that mimic the effluent-receiving water mixing conditions Results of these tests will be used to ensure that toxics in the effluent are controlled and to determine the need for future WET limits In addition the permit establishes toxicity trigger levels for each outfall (see Appendix C Section IVB ) that if exceeded trigger additional WET testing and potentially investigations to reduce toxicity
C Storm Water Monitoring
The current permit requires TCMC to monitor the receiving water upstream and downstream of the Outfall 003 sediment ponds for turbidity The monitoring is specified as weekly during
15
February through June and monthly for the other months of the year The draft permit continues this turbidity monitoring In addition the draft permit requires daily monitoring of effluent flow and monthly monitoring of Outfall 003 for metals (cadmium copper lead mercury and zinc) hardness TSS pH and temperature to ensure that water quality standards are maintained
The storm water discharge should not adversely affect water quality This assumes appropriate design and implementation of best management practices (BMPs) in lieu of numerical effluent limits The monitoring required in the draft permit along with periodic inspections are required to evaluate the effectiveness of BMPs and to provide sufficient information to determine if these discharges either cause or contribute to water quality standards exceedences Section VIIB below discusses the BMP requirements
D Receiving Water Monitoring
The current permit requires TCMC to provide for water quality monitoring in accordance with the program agreed upon by the Interagency Task Force (members of which include the USFS BLM IDEQ EPA and TCMC) TCMCrsquos current environmental monitoring program is described in the Consolidated Environmental Monitoring Program (TCMC 1999a) This program includes monitoring of the surface water sediments and aquatic biology in the receiving waters
The draft permit requires TCMC to continue this monitoring as it relates to the permitted discharges by specifying monitoring at selected locations within and around the discharge areas The water quality monitoring requirements in the draft permit are for the most part consistent with TCMCrsquos Consolidated Monitoring Program However some additional monitoring has been added since two new outfalls are proposed (004 and 005) one of the new outfalls (005) discharges to a Special Resource Water and to verify that bioaccumulation is not of concern The following summarizes the monitoring requirements in the draft permit
Surface Water Quality Monitoring Surface water quality monitoring of the receiving waters is required four times per year upstream and downstream of each outfall for the parameters listed in Table 7 When there is a discharge from outfalls 004 or 005 the permit requires that the monitoring frequency for metals in the Salmon River be increased to monthly This was a requirement of IDEQrsquos preliminary CWA Section 401 Certification for discharge into a Special Resource Water (see also Section VIIIB) IDEQ also required that for each sampling event metals concentrations in the receiving water be compared to aquatic life chronic water quality criteria If the concentrations exceed the criteria then future sampling for that parameter will be expanded to determine 4-day average concentrations (since chronic criteria are expressed as 4shyday average concentrations)
The receiving water quality monitoring data is used to evaluate the water quality impacts of the NPDES discharges The data will also be used during the next permitting cycle to determine the need for incorporating and retaining water quality-based effluent limits into the permit In order to perform these evaluations it is necessary that the ambient monitoring use analytical methods
16
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 12: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/12.jpg)
Table 4 Effluent Limitations for Outfall 004
Parameter units Proposed Effluent Limitations1
at Squaw Creek flow lt 50 cfs2 at Squaw Creek flow $ 50 cfs2
Maximum Daily Monthly Average Maximum Daily Monthly Average
cadmium ugl 12 58 26 13
lbday 0084 0041 018 0091
chromium ugl 40 20 -shy -shy
lbday 028 014 -shy -shy
copper ugl 48 24 120 58
lbday 034 017 084 041
lead ugl 37 18 21 10
lbday 026 013 015 0070
mercury ugl 0037 0018 021 010
lbday 000026 000013 00015 000070
silver ugl -shy -shy 22 11
lbday -shy -shy 015 0077
zinc ugl 290 140 860 430
lbday 20 098 60 30
TSS mgl 30 20 30 20
pH su within the range of 65 - 90 within the range of 65 - 90
Footnotes 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be total 2 - The flow tiers are representative of flow upstream of the outfall
12
Table 5 Effluent Limitations for Outfall 005
Parameter units Proposed Effluent Limitationss
Maximum Daily Monthly Average
cadmium ugl 12 62
lbday 017 0090
copper ugl 120 59
lbday 17 086
lead ugl 21 10
lbday 030 015
mercury ugl 061 030
lbday 00089 00044
silver ugl 12 60
lbday 017 0087
zinc ugl 1000 500
lbday 15 73
TSS mgl 30 20
pH su within the range of 65 - 90
Footnote 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total
VI MONITORING REQUIREMENTS
Section 308 of the Clean Water Act and federal regulation 40 CFR 12244(i) require that monitoring be included in permits to determine compliance with effluent limitations Monitoring may also be required to gather data for future effluent limitations or to monitor effluent impacts on receiving water quality TCMC is responsible for conducting the monitoring and reporting the results to EPA on monthly DMRs and in annual reports This section describes the monitoring requirements in the draft permit
A Effluent Monitoring
The effluent monitoring requirements in the draft permit are summarized in Table 6 The monitoring frequency for outfalls 001 and 002 is the same as included in the current permit (monthly for most parameters) The monitoring frequency for most of the outfall 004 and 005
13
parameters is weekly More frequent monitoring and composite sampling was determined to be necessary for these outfalls due to the composition of the outfalls (process water) the more continuous nature of the discharges and the Special Resource status of the Salmon River (Outfall 005) Flow monitoring of the receiving waters is required for outfalls 001 002 and 004 to determine which set of tiered effluent limits apply and to calculate dilution ratios (outfalls 001 and 002 only) Monitoring of Outfall 003 is discussed in Section VIC below
Some of the water quality-based effluent limits in the draft permit are close to the capability of current analytical technology to detect andor quantify (close to method detection limits) To address this concern the draft permit contains a provision requiring TCMC to use analytical methods that can achieve a method detection limit less than the effluent limitation Method detection limits are the minimum levels that can be accurately detected by current analytical technology
Table 6 Effluent Monitoring Requirements
Parameter Outfalls 001 and 002 Outfalls 004 and 005
frequency sample type frequency sample type
dilution ratio daily calculation -shy -shy
outfall flow cfs continuous recording continuous recording
metals with effluent limits1 ugl monthly grab weekly 24-hour composite
molybdenum ugl quarterly grab quarterly 24-hour composite
selenium2 ugl monthly grab quarterly 24-hour composite
TSS mgl weekly grab weekly 24-hour composite
pH standard units (su) weekly grab daily grab
hardness as CaCO3 mgl monthly grab weekly 24-hour composite
temperature oC weekly grab weekly grab
Acute WET3 TUa annually grab annually 24-hour composite
Chronic WET3 TUc annually grab quarterly 24-hour composite
Thompson Creek Flow4 cfs daily recording daily recording
Squaw Creek Flow5 cfs daily recording daily recording
Footnotes 1 - metals to be measured include cadmium chromium (outfall 004 only) copper lead mercury selenium (outfalls 001 and 002 only) silver (outfalls 004 and 005 only) and zinc 2 - selenium monitoring required for outfalls 001 and 002 (see footnote 1) and 005 3 - See Section VIB below for specific information regarding the whole effluent toxicity (WET) monitoring 4 - Thompson Creek flow monitoring is required upstream of each outfalls 001 and 002 5 - Squaw Creek flow monitoring is required upstream of Outfall 004
14
B Whole Effluent Toxicity Testing
Whole effluent toxicity (WET) is defined as the aggregate toxic effect of an effluent measured directly by an aquatic toxicity test WET tests are standardized laboratory tests that measure the total toxic effect of an effluent by exposing organisms to the effluent and noting the effects There are two different durations of toxicity tests acute and chronic Acute toxicity tests measure the test organisms survival over a 96-hour test exposure period Chronic toxicity tests measure reductions in survival growth and reproduction over a 7-day exposure
TCMC has conducted limited WET testing on their effluents In 1993 one set of WET tests were performed on effluent from outfalls 001 and 002 and some of the sources of wastewater to outfalls 004 and 005 (LA and PBS wastewaters) Results indicated no acute toxicity Chronic toxicity was indicated for Outfall 001 and the LA and PBS wastewaters at 100 effluent however the tests were not performed at dilutions representing the mixing zones In 1999 TCMC conducted an additional set of WET tests on outfalls 001 and 002 These tests indicated no acute toxicity Chronic toxicity was indicated for one species tested on Outfall 002
Federal regulations at 40 CFR 12244(d)(1) require that permits contain limits on WET when a discharge has reasonable potential to cause or contribute to an exceedence of a water quality standard In Idaho the relevant water quality standard states that surface waters of the State shall be free from toxic substances in concentrations that impair designated beneficial uses (see Appendix C Table C-2) The TSD provides guidance on implementing WET testing in NPDES permits The preliminary CWA Section 401 Certification provided by IDEQ included specific WET testing requirements for this permit (see also Section VIIIB)
Because the limited amount of existing WET testing on the TCM effluents is not adequate to determine the need for WET effluent limits WET testing has been incorporated into the draft permit The draft permit requires TCMC to conduct acute WET testing annually on effluent from each outfall Chronic WET testing must be conducted annually for outfalls 001 and 002 and quarterly for outfalls 004 and 005 TCMC is required to perform the acute tests using the salmonid species Oncorhynchus mykiss (rainbow trout) and the chronic tests using both Pimephales promelas (fathead minnow) and Ceriodaphnia dubia (water fleas) Different species are used for testing to represent different aquatic phyla (fish and invertebrates) and because different species have different sensitivities The tests will be conducted at a range of dilutions that mimic the effluent-receiving water mixing conditions Results of these tests will be used to ensure that toxics in the effluent are controlled and to determine the need for future WET limits In addition the permit establishes toxicity trigger levels for each outfall (see Appendix C Section IVB ) that if exceeded trigger additional WET testing and potentially investigations to reduce toxicity
C Storm Water Monitoring
The current permit requires TCMC to monitor the receiving water upstream and downstream of the Outfall 003 sediment ponds for turbidity The monitoring is specified as weekly during
15
February through June and monthly for the other months of the year The draft permit continues this turbidity monitoring In addition the draft permit requires daily monitoring of effluent flow and monthly monitoring of Outfall 003 for metals (cadmium copper lead mercury and zinc) hardness TSS pH and temperature to ensure that water quality standards are maintained
The storm water discharge should not adversely affect water quality This assumes appropriate design and implementation of best management practices (BMPs) in lieu of numerical effluent limits The monitoring required in the draft permit along with periodic inspections are required to evaluate the effectiveness of BMPs and to provide sufficient information to determine if these discharges either cause or contribute to water quality standards exceedences Section VIIB below discusses the BMP requirements
D Receiving Water Monitoring
The current permit requires TCMC to provide for water quality monitoring in accordance with the program agreed upon by the Interagency Task Force (members of which include the USFS BLM IDEQ EPA and TCMC) TCMCrsquos current environmental monitoring program is described in the Consolidated Environmental Monitoring Program (TCMC 1999a) This program includes monitoring of the surface water sediments and aquatic biology in the receiving waters
The draft permit requires TCMC to continue this monitoring as it relates to the permitted discharges by specifying monitoring at selected locations within and around the discharge areas The water quality monitoring requirements in the draft permit are for the most part consistent with TCMCrsquos Consolidated Monitoring Program However some additional monitoring has been added since two new outfalls are proposed (004 and 005) one of the new outfalls (005) discharges to a Special Resource Water and to verify that bioaccumulation is not of concern The following summarizes the monitoring requirements in the draft permit
Surface Water Quality Monitoring Surface water quality monitoring of the receiving waters is required four times per year upstream and downstream of each outfall for the parameters listed in Table 7 When there is a discharge from outfalls 004 or 005 the permit requires that the monitoring frequency for metals in the Salmon River be increased to monthly This was a requirement of IDEQrsquos preliminary CWA Section 401 Certification for discharge into a Special Resource Water (see also Section VIIIB) IDEQ also required that for each sampling event metals concentrations in the receiving water be compared to aquatic life chronic water quality criteria If the concentrations exceed the criteria then future sampling for that parameter will be expanded to determine 4-day average concentrations (since chronic criteria are expressed as 4shyday average concentrations)
The receiving water quality monitoring data is used to evaluate the water quality impacts of the NPDES discharges The data will also be used during the next permitting cycle to determine the need for incorporating and retaining water quality-based effluent limits into the permit In order to perform these evaluations it is necessary that the ambient monitoring use analytical methods
16
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 13: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/13.jpg)
Table 5 Effluent Limitations for Outfall 005
Parameter units Proposed Effluent Limitationss
Maximum Daily Monthly Average
cadmium ugl 12 62
lbday 017 0090
copper ugl 120 59
lbday 17 086
lead ugl 21 10
lbday 030 015
mercury ugl 061 030
lbday 00089 00044
silver ugl 12 60
lbday 017 0087
zinc ugl 1000 500
lbday 15 73
TSS mgl 30 20
pH su within the range of 65 - 90
Footnote 1 - Metals concentrations to be measured as total recoverable except for mercury which is to be measured as total
VI MONITORING REQUIREMENTS
Section 308 of the Clean Water Act and federal regulation 40 CFR 12244(i) require that monitoring be included in permits to determine compliance with effluent limitations Monitoring may also be required to gather data for future effluent limitations or to monitor effluent impacts on receiving water quality TCMC is responsible for conducting the monitoring and reporting the results to EPA on monthly DMRs and in annual reports This section describes the monitoring requirements in the draft permit
A Effluent Monitoring
The effluent monitoring requirements in the draft permit are summarized in Table 6 The monitoring frequency for outfalls 001 and 002 is the same as included in the current permit (monthly for most parameters) The monitoring frequency for most of the outfall 004 and 005
13
parameters is weekly More frequent monitoring and composite sampling was determined to be necessary for these outfalls due to the composition of the outfalls (process water) the more continuous nature of the discharges and the Special Resource status of the Salmon River (Outfall 005) Flow monitoring of the receiving waters is required for outfalls 001 002 and 004 to determine which set of tiered effluent limits apply and to calculate dilution ratios (outfalls 001 and 002 only) Monitoring of Outfall 003 is discussed in Section VIC below
Some of the water quality-based effluent limits in the draft permit are close to the capability of current analytical technology to detect andor quantify (close to method detection limits) To address this concern the draft permit contains a provision requiring TCMC to use analytical methods that can achieve a method detection limit less than the effluent limitation Method detection limits are the minimum levels that can be accurately detected by current analytical technology
Table 6 Effluent Monitoring Requirements
Parameter Outfalls 001 and 002 Outfalls 004 and 005
frequency sample type frequency sample type
dilution ratio daily calculation -shy -shy
outfall flow cfs continuous recording continuous recording
metals with effluent limits1 ugl monthly grab weekly 24-hour composite
molybdenum ugl quarterly grab quarterly 24-hour composite
selenium2 ugl monthly grab quarterly 24-hour composite
TSS mgl weekly grab weekly 24-hour composite
pH standard units (su) weekly grab daily grab
hardness as CaCO3 mgl monthly grab weekly 24-hour composite
temperature oC weekly grab weekly grab
Acute WET3 TUa annually grab annually 24-hour composite
Chronic WET3 TUc annually grab quarterly 24-hour composite
Thompson Creek Flow4 cfs daily recording daily recording
Squaw Creek Flow5 cfs daily recording daily recording
Footnotes 1 - metals to be measured include cadmium chromium (outfall 004 only) copper lead mercury selenium (outfalls 001 and 002 only) silver (outfalls 004 and 005 only) and zinc 2 - selenium monitoring required for outfalls 001 and 002 (see footnote 1) and 005 3 - See Section VIB below for specific information regarding the whole effluent toxicity (WET) monitoring 4 - Thompson Creek flow monitoring is required upstream of each outfalls 001 and 002 5 - Squaw Creek flow monitoring is required upstream of Outfall 004
14
B Whole Effluent Toxicity Testing
Whole effluent toxicity (WET) is defined as the aggregate toxic effect of an effluent measured directly by an aquatic toxicity test WET tests are standardized laboratory tests that measure the total toxic effect of an effluent by exposing organisms to the effluent and noting the effects There are two different durations of toxicity tests acute and chronic Acute toxicity tests measure the test organisms survival over a 96-hour test exposure period Chronic toxicity tests measure reductions in survival growth and reproduction over a 7-day exposure
TCMC has conducted limited WET testing on their effluents In 1993 one set of WET tests were performed on effluent from outfalls 001 and 002 and some of the sources of wastewater to outfalls 004 and 005 (LA and PBS wastewaters) Results indicated no acute toxicity Chronic toxicity was indicated for Outfall 001 and the LA and PBS wastewaters at 100 effluent however the tests were not performed at dilutions representing the mixing zones In 1999 TCMC conducted an additional set of WET tests on outfalls 001 and 002 These tests indicated no acute toxicity Chronic toxicity was indicated for one species tested on Outfall 002
Federal regulations at 40 CFR 12244(d)(1) require that permits contain limits on WET when a discharge has reasonable potential to cause or contribute to an exceedence of a water quality standard In Idaho the relevant water quality standard states that surface waters of the State shall be free from toxic substances in concentrations that impair designated beneficial uses (see Appendix C Table C-2) The TSD provides guidance on implementing WET testing in NPDES permits The preliminary CWA Section 401 Certification provided by IDEQ included specific WET testing requirements for this permit (see also Section VIIIB)
Because the limited amount of existing WET testing on the TCM effluents is not adequate to determine the need for WET effluent limits WET testing has been incorporated into the draft permit The draft permit requires TCMC to conduct acute WET testing annually on effluent from each outfall Chronic WET testing must be conducted annually for outfalls 001 and 002 and quarterly for outfalls 004 and 005 TCMC is required to perform the acute tests using the salmonid species Oncorhynchus mykiss (rainbow trout) and the chronic tests using both Pimephales promelas (fathead minnow) and Ceriodaphnia dubia (water fleas) Different species are used for testing to represent different aquatic phyla (fish and invertebrates) and because different species have different sensitivities The tests will be conducted at a range of dilutions that mimic the effluent-receiving water mixing conditions Results of these tests will be used to ensure that toxics in the effluent are controlled and to determine the need for future WET limits In addition the permit establishes toxicity trigger levels for each outfall (see Appendix C Section IVB ) that if exceeded trigger additional WET testing and potentially investigations to reduce toxicity
C Storm Water Monitoring
The current permit requires TCMC to monitor the receiving water upstream and downstream of the Outfall 003 sediment ponds for turbidity The monitoring is specified as weekly during
15
February through June and monthly for the other months of the year The draft permit continues this turbidity monitoring In addition the draft permit requires daily monitoring of effluent flow and monthly monitoring of Outfall 003 for metals (cadmium copper lead mercury and zinc) hardness TSS pH and temperature to ensure that water quality standards are maintained
The storm water discharge should not adversely affect water quality This assumes appropriate design and implementation of best management practices (BMPs) in lieu of numerical effluent limits The monitoring required in the draft permit along with periodic inspections are required to evaluate the effectiveness of BMPs and to provide sufficient information to determine if these discharges either cause or contribute to water quality standards exceedences Section VIIB below discusses the BMP requirements
D Receiving Water Monitoring
The current permit requires TCMC to provide for water quality monitoring in accordance with the program agreed upon by the Interagency Task Force (members of which include the USFS BLM IDEQ EPA and TCMC) TCMCrsquos current environmental monitoring program is described in the Consolidated Environmental Monitoring Program (TCMC 1999a) This program includes monitoring of the surface water sediments and aquatic biology in the receiving waters
The draft permit requires TCMC to continue this monitoring as it relates to the permitted discharges by specifying monitoring at selected locations within and around the discharge areas The water quality monitoring requirements in the draft permit are for the most part consistent with TCMCrsquos Consolidated Monitoring Program However some additional monitoring has been added since two new outfalls are proposed (004 and 005) one of the new outfalls (005) discharges to a Special Resource Water and to verify that bioaccumulation is not of concern The following summarizes the monitoring requirements in the draft permit
Surface Water Quality Monitoring Surface water quality monitoring of the receiving waters is required four times per year upstream and downstream of each outfall for the parameters listed in Table 7 When there is a discharge from outfalls 004 or 005 the permit requires that the monitoring frequency for metals in the Salmon River be increased to monthly This was a requirement of IDEQrsquos preliminary CWA Section 401 Certification for discharge into a Special Resource Water (see also Section VIIIB) IDEQ also required that for each sampling event metals concentrations in the receiving water be compared to aquatic life chronic water quality criteria If the concentrations exceed the criteria then future sampling for that parameter will be expanded to determine 4-day average concentrations (since chronic criteria are expressed as 4shyday average concentrations)
The receiving water quality monitoring data is used to evaluate the water quality impacts of the NPDES discharges The data will also be used during the next permitting cycle to determine the need for incorporating and retaining water quality-based effluent limits into the permit In order to perform these evaluations it is necessary that the ambient monitoring use analytical methods
16
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 14: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/14.jpg)
parameters is weekly More frequent monitoring and composite sampling was determined to be necessary for these outfalls due to the composition of the outfalls (process water) the more continuous nature of the discharges and the Special Resource status of the Salmon River (Outfall 005) Flow monitoring of the receiving waters is required for outfalls 001 002 and 004 to determine which set of tiered effluent limits apply and to calculate dilution ratios (outfalls 001 and 002 only) Monitoring of Outfall 003 is discussed in Section VIC below
Some of the water quality-based effluent limits in the draft permit are close to the capability of current analytical technology to detect andor quantify (close to method detection limits) To address this concern the draft permit contains a provision requiring TCMC to use analytical methods that can achieve a method detection limit less than the effluent limitation Method detection limits are the minimum levels that can be accurately detected by current analytical technology
Table 6 Effluent Monitoring Requirements
Parameter Outfalls 001 and 002 Outfalls 004 and 005
frequency sample type frequency sample type
dilution ratio daily calculation -shy -shy
outfall flow cfs continuous recording continuous recording
metals with effluent limits1 ugl monthly grab weekly 24-hour composite
molybdenum ugl quarterly grab quarterly 24-hour composite
selenium2 ugl monthly grab quarterly 24-hour composite
TSS mgl weekly grab weekly 24-hour composite
pH standard units (su) weekly grab daily grab
hardness as CaCO3 mgl monthly grab weekly 24-hour composite
temperature oC weekly grab weekly grab
Acute WET3 TUa annually grab annually 24-hour composite
Chronic WET3 TUc annually grab quarterly 24-hour composite
Thompson Creek Flow4 cfs daily recording daily recording
Squaw Creek Flow5 cfs daily recording daily recording
Footnotes 1 - metals to be measured include cadmium chromium (outfall 004 only) copper lead mercury selenium (outfalls 001 and 002 only) silver (outfalls 004 and 005 only) and zinc 2 - selenium monitoring required for outfalls 001 and 002 (see footnote 1) and 005 3 - See Section VIB below for specific information regarding the whole effluent toxicity (WET) monitoring 4 - Thompson Creek flow monitoring is required upstream of each outfalls 001 and 002 5 - Squaw Creek flow monitoring is required upstream of Outfall 004
14
B Whole Effluent Toxicity Testing
Whole effluent toxicity (WET) is defined as the aggregate toxic effect of an effluent measured directly by an aquatic toxicity test WET tests are standardized laboratory tests that measure the total toxic effect of an effluent by exposing organisms to the effluent and noting the effects There are two different durations of toxicity tests acute and chronic Acute toxicity tests measure the test organisms survival over a 96-hour test exposure period Chronic toxicity tests measure reductions in survival growth and reproduction over a 7-day exposure
TCMC has conducted limited WET testing on their effluents In 1993 one set of WET tests were performed on effluent from outfalls 001 and 002 and some of the sources of wastewater to outfalls 004 and 005 (LA and PBS wastewaters) Results indicated no acute toxicity Chronic toxicity was indicated for Outfall 001 and the LA and PBS wastewaters at 100 effluent however the tests were not performed at dilutions representing the mixing zones In 1999 TCMC conducted an additional set of WET tests on outfalls 001 and 002 These tests indicated no acute toxicity Chronic toxicity was indicated for one species tested on Outfall 002
Federal regulations at 40 CFR 12244(d)(1) require that permits contain limits on WET when a discharge has reasonable potential to cause or contribute to an exceedence of a water quality standard In Idaho the relevant water quality standard states that surface waters of the State shall be free from toxic substances in concentrations that impair designated beneficial uses (see Appendix C Table C-2) The TSD provides guidance on implementing WET testing in NPDES permits The preliminary CWA Section 401 Certification provided by IDEQ included specific WET testing requirements for this permit (see also Section VIIIB)
Because the limited amount of existing WET testing on the TCM effluents is not adequate to determine the need for WET effluent limits WET testing has been incorporated into the draft permit The draft permit requires TCMC to conduct acute WET testing annually on effluent from each outfall Chronic WET testing must be conducted annually for outfalls 001 and 002 and quarterly for outfalls 004 and 005 TCMC is required to perform the acute tests using the salmonid species Oncorhynchus mykiss (rainbow trout) and the chronic tests using both Pimephales promelas (fathead minnow) and Ceriodaphnia dubia (water fleas) Different species are used for testing to represent different aquatic phyla (fish and invertebrates) and because different species have different sensitivities The tests will be conducted at a range of dilutions that mimic the effluent-receiving water mixing conditions Results of these tests will be used to ensure that toxics in the effluent are controlled and to determine the need for future WET limits In addition the permit establishes toxicity trigger levels for each outfall (see Appendix C Section IVB ) that if exceeded trigger additional WET testing and potentially investigations to reduce toxicity
C Storm Water Monitoring
The current permit requires TCMC to monitor the receiving water upstream and downstream of the Outfall 003 sediment ponds for turbidity The monitoring is specified as weekly during
15
February through June and monthly for the other months of the year The draft permit continues this turbidity monitoring In addition the draft permit requires daily monitoring of effluent flow and monthly monitoring of Outfall 003 for metals (cadmium copper lead mercury and zinc) hardness TSS pH and temperature to ensure that water quality standards are maintained
The storm water discharge should not adversely affect water quality This assumes appropriate design and implementation of best management practices (BMPs) in lieu of numerical effluent limits The monitoring required in the draft permit along with periodic inspections are required to evaluate the effectiveness of BMPs and to provide sufficient information to determine if these discharges either cause or contribute to water quality standards exceedences Section VIIB below discusses the BMP requirements
D Receiving Water Monitoring
The current permit requires TCMC to provide for water quality monitoring in accordance with the program agreed upon by the Interagency Task Force (members of which include the USFS BLM IDEQ EPA and TCMC) TCMCrsquos current environmental monitoring program is described in the Consolidated Environmental Monitoring Program (TCMC 1999a) This program includes monitoring of the surface water sediments and aquatic biology in the receiving waters
The draft permit requires TCMC to continue this monitoring as it relates to the permitted discharges by specifying monitoring at selected locations within and around the discharge areas The water quality monitoring requirements in the draft permit are for the most part consistent with TCMCrsquos Consolidated Monitoring Program However some additional monitoring has been added since two new outfalls are proposed (004 and 005) one of the new outfalls (005) discharges to a Special Resource Water and to verify that bioaccumulation is not of concern The following summarizes the monitoring requirements in the draft permit
Surface Water Quality Monitoring Surface water quality monitoring of the receiving waters is required four times per year upstream and downstream of each outfall for the parameters listed in Table 7 When there is a discharge from outfalls 004 or 005 the permit requires that the monitoring frequency for metals in the Salmon River be increased to monthly This was a requirement of IDEQrsquos preliminary CWA Section 401 Certification for discharge into a Special Resource Water (see also Section VIIIB) IDEQ also required that for each sampling event metals concentrations in the receiving water be compared to aquatic life chronic water quality criteria If the concentrations exceed the criteria then future sampling for that parameter will be expanded to determine 4-day average concentrations (since chronic criteria are expressed as 4shyday average concentrations)
The receiving water quality monitoring data is used to evaluate the water quality impacts of the NPDES discharges The data will also be used during the next permitting cycle to determine the need for incorporating and retaining water quality-based effluent limits into the permit In order to perform these evaluations it is necessary that the ambient monitoring use analytical methods
16
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 15: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/15.jpg)
B Whole Effluent Toxicity Testing
Whole effluent toxicity (WET) is defined as the aggregate toxic effect of an effluent measured directly by an aquatic toxicity test WET tests are standardized laboratory tests that measure the total toxic effect of an effluent by exposing organisms to the effluent and noting the effects There are two different durations of toxicity tests acute and chronic Acute toxicity tests measure the test organisms survival over a 96-hour test exposure period Chronic toxicity tests measure reductions in survival growth and reproduction over a 7-day exposure
TCMC has conducted limited WET testing on their effluents In 1993 one set of WET tests were performed on effluent from outfalls 001 and 002 and some of the sources of wastewater to outfalls 004 and 005 (LA and PBS wastewaters) Results indicated no acute toxicity Chronic toxicity was indicated for Outfall 001 and the LA and PBS wastewaters at 100 effluent however the tests were not performed at dilutions representing the mixing zones In 1999 TCMC conducted an additional set of WET tests on outfalls 001 and 002 These tests indicated no acute toxicity Chronic toxicity was indicated for one species tested on Outfall 002
Federal regulations at 40 CFR 12244(d)(1) require that permits contain limits on WET when a discharge has reasonable potential to cause or contribute to an exceedence of a water quality standard In Idaho the relevant water quality standard states that surface waters of the State shall be free from toxic substances in concentrations that impair designated beneficial uses (see Appendix C Table C-2) The TSD provides guidance on implementing WET testing in NPDES permits The preliminary CWA Section 401 Certification provided by IDEQ included specific WET testing requirements for this permit (see also Section VIIIB)
Because the limited amount of existing WET testing on the TCM effluents is not adequate to determine the need for WET effluent limits WET testing has been incorporated into the draft permit The draft permit requires TCMC to conduct acute WET testing annually on effluent from each outfall Chronic WET testing must be conducted annually for outfalls 001 and 002 and quarterly for outfalls 004 and 005 TCMC is required to perform the acute tests using the salmonid species Oncorhynchus mykiss (rainbow trout) and the chronic tests using both Pimephales promelas (fathead minnow) and Ceriodaphnia dubia (water fleas) Different species are used for testing to represent different aquatic phyla (fish and invertebrates) and because different species have different sensitivities The tests will be conducted at a range of dilutions that mimic the effluent-receiving water mixing conditions Results of these tests will be used to ensure that toxics in the effluent are controlled and to determine the need for future WET limits In addition the permit establishes toxicity trigger levels for each outfall (see Appendix C Section IVB ) that if exceeded trigger additional WET testing and potentially investigations to reduce toxicity
C Storm Water Monitoring
The current permit requires TCMC to monitor the receiving water upstream and downstream of the Outfall 003 sediment ponds for turbidity The monitoring is specified as weekly during
15
February through June and monthly for the other months of the year The draft permit continues this turbidity monitoring In addition the draft permit requires daily monitoring of effluent flow and monthly monitoring of Outfall 003 for metals (cadmium copper lead mercury and zinc) hardness TSS pH and temperature to ensure that water quality standards are maintained
The storm water discharge should not adversely affect water quality This assumes appropriate design and implementation of best management practices (BMPs) in lieu of numerical effluent limits The monitoring required in the draft permit along with periodic inspections are required to evaluate the effectiveness of BMPs and to provide sufficient information to determine if these discharges either cause or contribute to water quality standards exceedences Section VIIB below discusses the BMP requirements
D Receiving Water Monitoring
The current permit requires TCMC to provide for water quality monitoring in accordance with the program agreed upon by the Interagency Task Force (members of which include the USFS BLM IDEQ EPA and TCMC) TCMCrsquos current environmental monitoring program is described in the Consolidated Environmental Monitoring Program (TCMC 1999a) This program includes monitoring of the surface water sediments and aquatic biology in the receiving waters
The draft permit requires TCMC to continue this monitoring as it relates to the permitted discharges by specifying monitoring at selected locations within and around the discharge areas The water quality monitoring requirements in the draft permit are for the most part consistent with TCMCrsquos Consolidated Monitoring Program However some additional monitoring has been added since two new outfalls are proposed (004 and 005) one of the new outfalls (005) discharges to a Special Resource Water and to verify that bioaccumulation is not of concern The following summarizes the monitoring requirements in the draft permit
Surface Water Quality Monitoring Surface water quality monitoring of the receiving waters is required four times per year upstream and downstream of each outfall for the parameters listed in Table 7 When there is a discharge from outfalls 004 or 005 the permit requires that the monitoring frequency for metals in the Salmon River be increased to monthly This was a requirement of IDEQrsquos preliminary CWA Section 401 Certification for discharge into a Special Resource Water (see also Section VIIIB) IDEQ also required that for each sampling event metals concentrations in the receiving water be compared to aquatic life chronic water quality criteria If the concentrations exceed the criteria then future sampling for that parameter will be expanded to determine 4-day average concentrations (since chronic criteria are expressed as 4shyday average concentrations)
The receiving water quality monitoring data is used to evaluate the water quality impacts of the NPDES discharges The data will also be used during the next permitting cycle to determine the need for incorporating and retaining water quality-based effluent limits into the permit In order to perform these evaluations it is necessary that the ambient monitoring use analytical methods
16
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 16: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/16.jpg)
February through June and monthly for the other months of the year The draft permit continues this turbidity monitoring In addition the draft permit requires daily monitoring of effluent flow and monthly monitoring of Outfall 003 for metals (cadmium copper lead mercury and zinc) hardness TSS pH and temperature to ensure that water quality standards are maintained
The storm water discharge should not adversely affect water quality This assumes appropriate design and implementation of best management practices (BMPs) in lieu of numerical effluent limits The monitoring required in the draft permit along with periodic inspections are required to evaluate the effectiveness of BMPs and to provide sufficient information to determine if these discharges either cause or contribute to water quality standards exceedences Section VIIB below discusses the BMP requirements
D Receiving Water Monitoring
The current permit requires TCMC to provide for water quality monitoring in accordance with the program agreed upon by the Interagency Task Force (members of which include the USFS BLM IDEQ EPA and TCMC) TCMCrsquos current environmental monitoring program is described in the Consolidated Environmental Monitoring Program (TCMC 1999a) This program includes monitoring of the surface water sediments and aquatic biology in the receiving waters
The draft permit requires TCMC to continue this monitoring as it relates to the permitted discharges by specifying monitoring at selected locations within and around the discharge areas The water quality monitoring requirements in the draft permit are for the most part consistent with TCMCrsquos Consolidated Monitoring Program However some additional monitoring has been added since two new outfalls are proposed (004 and 005) one of the new outfalls (005) discharges to a Special Resource Water and to verify that bioaccumulation is not of concern The following summarizes the monitoring requirements in the draft permit
Surface Water Quality Monitoring Surface water quality monitoring of the receiving waters is required four times per year upstream and downstream of each outfall for the parameters listed in Table 7 When there is a discharge from outfalls 004 or 005 the permit requires that the monitoring frequency for metals in the Salmon River be increased to monthly This was a requirement of IDEQrsquos preliminary CWA Section 401 Certification for discharge into a Special Resource Water (see also Section VIIIB) IDEQ also required that for each sampling event metals concentrations in the receiving water be compared to aquatic life chronic water quality criteria If the concentrations exceed the criteria then future sampling for that parameter will be expanded to determine 4-day average concentrations (since chronic criteria are expressed as 4shyday average concentrations)
The receiving water quality monitoring data is used to evaluate the water quality impacts of the NPDES discharges The data will also be used during the next permitting cycle to determine the need for incorporating and retaining water quality-based effluent limits into the permit In order to perform these evaluations it is necessary that the ambient monitoring use analytical methods
16
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 17: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/17.jpg)
that have method detection limits below the water quality criteria Therefore the draft permit specifies method detection limits for metals required for surface water monitoring (see Table 7 of the draft permit)
Table 7 Surface Water Quality Monitoring Requirements
Monitoring Locations1
Monitoring Frequency Parameters
Thompson Creek Stations TC-1 TC-2 TC-3 TC-4
4 times per year2 for all parameters Metals3 Cadmium Chromium-VI (Squaw Creek only) Copper Lead Mercury Molybdenum Selenium (Thompson Creek and Salmon River
only) Silver (Squaw Creek and Salmon River only) Zinc
Total Suspended Solids (TSS) pH Temperature Turbidity Hardness Dissolved Oxygen
Squaw Creek Stations SQ-2 and SQ-3
Salmon River Stations SR-1 and SR-3
4 times per year2 for all parameters
In addition when there is a discharge from outfalls 004 or 005 monthly monitoring for metals (except molybdenum) is required
Footnotes 1 - See Figure A-2 in Appendix A for a map showing the monitoring locations 2 - Monitoring is required during spring low flow (April) spring high flow (June) summer low flow (August) and fall low flow (October) 3 - Metals must be monitored and reported as dissolved except for mercury which must be monitored as total and molybdenum and selenium which must be monitored as total recoverable
Bioassessment Program Under the Consolidated Environmental Monitoring Program TCMC currently monitors Thompson Creek and Squaw Creek upstream and downstream from the NPDES outfalls for benthic macroinvertebrates and fish The proposed permit contains requirements to continue to monitor benthic macroinvertebrates annually and fish bi-annually at these locations and expands the monitoring to include the Salmon River upstream and downstream of Outfall 005 As requested by IDEQ in their preliminary certification the proposed permit also requires annual monitoring of periphyton at these locations
The purpose of the bioassessment program is to monitor and evaluate changes in the receiving water biological community that may occur as a result of activities associated with the discharges from the facility If the results of the bioassessment monitoring indicate downstream differences in comparison to the upstream station or declining trends over time the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
17
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 18: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/18.jpg)
Bioaccumulation Study Pursuant to the preliminary certification from IDEQ the proposed permit requires that TCMC conduct a bioaccumulation study to determine whether exposure to mercury or selenium through bioaccumulation poses a risk of adverse effects to aquatic life in Thompson Creek Mercury and selenium are parameters of concern due to their potential to bioaccumulate (become concentrated in living organisms and move up the food chain) Specifically the draft permit requires sampling and analysis of sediment aufwuchs (periphyton and abiotic material embedded in the periphyton) macroinvertebrates and fish (sculpin or trout) upstream and downstream of outfalls 001 and 002 for mercury and selenium Sampling is only required for Thompson Creek since it has received long-term discharges from outfalls 001 and 002
If the results of the study indicate downstream differences in comparison to the upstream station or exceedences of the biological screening levels in the draft permit (see Table 9 of the draft permit) the proposed permit requires that TCMC undertake an investigation to identify and remedy the cause
E Representative Sampling
The draft permit has expanded the requirement in the federal regulations regarding representative sampling (40 CFR 12241[j]) This provision now specifically requires representative sampling whenever a bypass spill or non-routine discharge of pollutants occurs if the discharge may reasonably be expected to cause or contribute to a violation of an effluent limit under the permit This provision is included in the draft permit because routine monitoring could miss permit violations andor water quality standards exceedences that could result from bypasses spills or non-routine discharges This requirement directs TCMC to conduct additional targeted monitoring to quantify the effects of these occurrences on the final effluent discharge
VII OTHER PERMIT CONDITIONS
A Quality Assurance Plan
Federal regulations at 40 CFR 12241(e) require permittees to properly operate and maintain their facilities including ldquoadequate laboratory controls and appropriate quality assurance proceduresrdquo To implement this requirement the draft permit requires that TCMC develop a Quality Assurance Plan (QAP) to ensure that the monitoring data submitted is accurate and to explain data anomalies if they occur The QAP must include standard operating procedures the permittee must follow for collecting handling storing and shipping samples laboratory analysis and data reporting The draft permit requires TCMC to submit the QAP to EPA within 60 days of the effective date of the permit and implement the QAP within 120 days of the effective date
B Best Management Practices Plan
18
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 19: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/19.jpg)
Section 402 of the Clean Water Act and federal regulations at 40 CFR 12244(k)(2) and (3) authorize EPA to require best management practices (BMPs) in NPDES permits BMPs are measures that are intended to prevent or minimize the generation and the potential for release of pollutants from industrial facilities to waters of the US These measures are important tools for waste minimization and pollution prevention
The draft permit requires TCMC to prepare and implement a BMP Plan within 120 days and 180 days respectively of permit issuance The BMP Plan is intended to achieve the following objectives minimize the quantity of pollutants discharged from the facility reduce the toxicity of discharges to the extent practicable prevent the entry of pollutants into waste streams and minimize storm water contamination The BMP Plan will apply to all components of the TCM The draft permit requires that the BMP Plan be maintained and that any modifications to the facility are made with consideration to the effect the modification could have on the generation or potential release of pollutants The BMP Plan must be revised if the facility is modified and as new pollution prevention practices are developed
The draft permit also requires comprehensive site compliance evaluations and submittal of annual reports documenting the compliance evaluations observations related to implementation of the BMP Plan any incidents of non-compliance and any corrective actions and BMP Plan modifications over the year
C Additional Permit Provisions
In addition to facility-specific requirements most of sections III IV and V of the draft permit contain ldquoboilerplaterdquo requirements Boilerplate is standard regulatory language that applies to all permittees and must be included in NPDES permits Because the boilerplate requirements are based on regulations they cannot be challenged in the context of an NPDES permit action The boilerplate covers requirements such as monitoring recording reporting requirements compliance responsibilities and general requirements
VIII OTHER LEGAL REQUIREMENTS
A Endangered Species Act
The Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service and the US Fish and Wildlife Service (collectively referred to as the Services) if their actions could beneficially or adversely affect any threatened or endangered species The Services have identified several threatened and endangered species in the vicinity of TCM discharges EPA has initiated informal consultation with NMFS and the USFWS including preparation of a Biological Evaluation to evaluate the potential impacts of the NPDES discharges on the listed species If the consultation results in reasonable and prudent measures or alternatives that require more stringent permit conditions EPA will incorporate those conditions
19
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 20: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/20.jpg)
into the final permit Appendix E provides further information on the listed species and consultation process
B State Certification
Section 401 of the Clean Water Act requires EPA to seek certification from the State that the permit is adequate to meet State water quality standards before issuing a final permit The regulations allow for the state to stipulate more stringent conditions in the permit if the certification cites the Clean Water Act or State law references upon which that condition is based In addition the regulations require a certification to include statements of the extent to which each condition of the permit can be made less stringent without violating the requirements of State law
The State provided EPA with a preliminary certification of this permit (IDEQ 2000) The preliminary certification contained the following requirements that have been incorporated into the draft permit
Mixing Zones IDEQ proposed mixing zones for outfalls 001 002 004 and 005 The water quality-based limits in the draft permit are based on the dilution available in those mixing zones (see Appendix C Section IIIB)
WET Testing IDEQ specified requirements for WET testing of the effluents
Receiving Water Monitoring IDEQ proposed specific monitoring requirements for the surface water quality monitoring bioassessment monitoring and the bioaccumulation study as discussed in Section VIC
Special Resource Water Monitoring The designation of the Salmon River as a Special Resource Water imparts specific considerations to ensure protection of the Salmon River from new and increased point source discharges Therefore in addition to the receiving water monitoring recommendations for all the receiving waters IDEQ provided additional requirements for monitoring the Salmon River (more frequent monitoring statistical analysis of results to detect differences etc)
Compliance Schedule for Selenium New selenium limits have been established for outfalls 001 and 002 The State water quality standards includes a provision for compliance schedules which allow a discharger to phase in over time compliance with new water quality-based limits The preliminary certification included a compliance schedule that allows TCMC up to five years to achieve compliance with the selenium effluent limits Since compliance schedules must be less than the effective life of the permit (which is 5 years) the deadline for compliance was set at 4 years and 11 months The compliance schedule specified work that TCMC must perform and report each year until compliance is achieved (see Table 9 of the draft permit)
20
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 21: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/21.jpg)
The above recommendations have been incorporated into the draft permit After the public comment period a preliminary final permit will be sent to the State for final certification If the State authorizes different requirements in its final certification EPA will incorporate those requirements into the permit For example if the State authorizes different mixing zones in its final certification EPA will recalculate the effluent limitations in the final permit based on the dilution available in the final mixing zones
C Antidegradation
In setting permit limitations EPA must consider the Statersquos antidegradation policy This policy is designed to protect existing water quality when the existing quality is better than that required to meet the standard and to prevent water quality from being degraded below the standard when existing quality just meets the standard For high quality waters antidegradation requires that the State find that allowing lower water quality is necessary to accommodate important economic or social development before any degradation is authorized This means that if water quality is better than necessary to meet the water quality standards increased permit limits can be authorized only if they do not cause degradation or if the State makes the determination that it is necessary
The current permit has effluent limitations for arsenic for outfalls 001 and 002 Since the reasonable potential analysis indicated no reasonable potential to cause or contribute to an exceedence of water quality criteria limits for arsenic were not included in the draft permit
Because the effluent limits in the draft permit are based on current water quality criteria or technology-based limits that have been shown to not cause or contribute to an exceedence of water quality standards the discharges as authorized in the draft permit will not result in degradation of the receiving water In addition the State presented an antidegradation analysis for the new discharge to the Salmon River Therefore the conditions in the permit will comply with the Statersquos antidegradation requirements
D Permit Expiration
This permit will expire five years from the effective date of the permit
21
APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
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APPENDIX A - TCMC FACILITY MAPS
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 23: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/23.jpg)
APPENDIX B - TCM WASTE STREAMS
As a supplement to Section II of the Fact Sheet this appendix describes wastewater management and discharges from the TCM Following is a description of each of the waste streams currently discharged from the facility (outfalls 001 002 and 003) and proposed for discharge from the facility (outfalls 004 and 005) A map of the discharge locations is provided in Appendix A (Figure A-2)
Outfall 001
This outfall discharges seepage and surface run-off from the Buckskin waste rock dump The Buckskin waste rock dump overlies Buckskin Creek A series of subdrains constructed underneath the dump are used to collect infiltration and seepage from beneath the waste rock The subdrains flow to a sediment pond at the bottom of the waste rock dump Run-off from the surface of the waste rock dump is also routed to the sediment pond The sediment pond serves to trap soil and other fines eroded from the dump area and to provide settling The sediment pond is designed to provide for 24-hour retention of average springtime flows in addition to the equivalent of the 10-year 24-hour storm event Overflow from the pond (designated Outfall 001) is discharged to Buckskin Creek approximately 2000 feet above the confluence of Thompson Creek The discharge is intermittent in nature generally present only during the months of April through August The flow is highly influenced by precipitation and snow melt Based on flow data reported by TCMC in Discharge Monitoring Reports (DMRs) over the last five years the average flow of Outfall 001 when it is discharging is 12 cfs The maximum flow reported was 84 cfs
Pollutants of concern in Outfall 001 include metals (aluminum antimony arsenic cadmium chromium cobalt copper iron lead manganese mercury molybdenum nickel selenium silver and zinc) total suspended solids (TSS) and pH
Outfall 002
This outfall discharges seepage and surface run-off from the Pat Hughes waste rock dump The Pat Hughes waste rock dump overlies Pat Hughes Creek The waste water management (subdrains and sediment pond) is the same as described for the Buckskin dump The only difference is that the sediment pond also collects the diverted flow of upper Pat Hughes Creek (which is routed around the waste rock dump) Overflow from the Pat Hughes sediment pond (designated Outfall 002) is discharged to Pat Hughes Creek approximately 2000 feet above the confluence with Thompson Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on DMR data over the last five years the average and maximum flows from Outfall 002 were 07 cfs and 12 cfs respectively The pollutants of concern are the same as for Outfall 001
B-1
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 24: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/24.jpg)
Outfall 003
Storm water runoff from the mill and mine roads is collected in ditches which drain to a series of two in-stream sediment ponds located in lower Bruno Creek As discussed under Outfall 004 below flows in upper Bruno Creek are either diverted around the tailings impoundment or are captured for use as process water in the mill When Bruno Creek flow is diverted around the impoundment the diverted flow reenters the lower Bruno Creek channel and the sediment ponds Twin Apex Creek flows into Bruno Creek above the sediment ponds An inactive mine (the Twin Apex Mine) discharges into Twin Apex Creek Therefore the sediment ponds contain flows from storm water Twin Apex Creek and at times the Bruno Creek diversion
Overflow from the sediment ponds (designated Outfall 003) is discharged to Bruno Creek just above the confluence of Squaw Creek The discharge experiences peak flows during May through July and has continuous low flows during the remainder of the year Based on monitoring conducted by TCMC the yearly average and maximum flows from Outfall 003 are 11 cfs and 97 cfs respectively
The pollutants of concern in Outfall 003 include suspended solids
Outfall 004
Mine water from the open pit mine and tailings from the mill are disposed of in a tailings impoundment that is constructed across the upper Bruno Creek catchment Flows from Bruno Creek are either diverted around the impoundment or are captured for use in the mill The impoundment serves to separate the water and solids portions of the tailings via settling Water is reclaimed from the surface of the impoundment and pumped to the mill for reuse A system of drains underneath the impoundment and embankment collect drainage which flows to a seepage return dam (SRD) located below the impoundment Wastewater from the SRD is pumped to the mill for reuse or back to the tailings impoundment The SRD was originally planned to contain all seepage from the tailings impoundment however seepage was identified downstream of the SRD This seepage is collected via a lined sump and pumped back to the SRD (this wastewater stream is called pumpback system water (PBS))
The tailings impoundment water management system was designed and is operated as a closed system with zero discharge During operation and normal precipitation the water entering the tailings pond (tailings water and precipitation) is balanced by the water exiting the pond (for use in the mill) During times of reduced milling operations no operation or abnormally wet water years water accumulates in the pond This accumulated water must periodically be discharged to maintain the stability of the dam as designed The new outfalls 004 and 005 were designed to accommodate this need
Discharge from Outfall 004 will consist of waste water collected from the tailings embankment left abutment drain (LA) and pumpback system water (PBS) These collected flows will be
B-2
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 25: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/25.jpg)
piped to discharge in Squaw Creek at the confluence with Bruno Creek TCMC is installing a diffuser to allow for efficient mixing in Squaw Creek Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 004 is estimated at 13 cfs (1 cfs from the LA and 03 cfs from the PBS) Pollutants of concern in Outfall 004 include metals TSS and pH
Outfall 005
During periods when the mine is not operating water will not be withdrawn from the tailings impoundment for reuse This water needs to be discharged to maintain a safe water level in the impoundment Outfall 004 alone would not provide enough discharge capacity to reduce the water level Therefore an additional outfall is included in the draft permit Outfall 005 will include the same sources of wastewater as Outfall 004 (LA and PBS water) as well as wastewater collected from the open pit mine (PIT) These wastewaters will be discharged through the existing mine make-up water underground pipeline directly to the Salmon River just below the confluence with Thompson Creek TCMC is installing a custom designed diffuser on the pipeline to allow for efficient mixing in the river Based on flow volume monitoring conducted by TCMC over the last three years the maximum flow of Outfall 005 is estimated as 27 cfs (10 cfs from the LA 03 cfs from the PBS and 14 cfs from PIT) Pollutants of concern include metals TSS and pH
TCMC submitted a permit application for discharging effluent from either or both of Outfalls 001 and 002 through Outfall 005 to the Salmon River Therefore the source of wastewater in Outfall 005 may consist of the LA PBS and PIT wastewaters andor Outfall 001 and 002 wastewaters
B-3
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 26: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/26.jpg)
APPENDIX C - DEVELOPMENT OF EFFLUENT LIMITATIONS
This section discusses the basis for and the development of effluent limits in the draft permit This section includes an overall discussion of the statutory and regulatory basis for development of effluent limitations (Section I) discussions of the development of technology-based effluent limits (Section II) and water quality-based effluent limits (Section III) and a summary of the effluent limits developed for this draft permit (Section IV)
I Statutory and Regulatory Basis for Limits
Sections 101 301(b) 304 308 401 402 and 405 of the Clean Water Act (CWA) provide the basis for the effluent limitations and other conditions in the draft permit The EPA evaluates the discharges with respect to these sections of the CWA and the relevant National Pollutant Discharge Elimination System (NPDES) regulations to determine which conditions to include in the draft permit
In general the EPA first determines which technology-based limits must be incorporated into the permit EPA then evaluates the effluent quality expected to result from these controls to see if it could result in any exceedances of the water quality standards in the receiving water If exceedances could occur EPA must include water quality-based limits in the permit The proposed permit limits will reflect whichever requirements (technology-based or water quality-based) are more stringent
II Technology-based Evaluation
Section 301(b) of the CWA requires technology-based controls on effluents This section of the Clean Water Act requires that by March 31 1989 all permits contain effluent limitations which (1) control toxic pollutants and nonconventional pollutants through the use of ldquobest available technology economically achievablerdquo (BAT) and (2) represent ldquobest conventional pollutant control technologyrdquo (BCT) for conventional pollutants by March 31 1989 In no case may BCT or BAT be less stringent than ldquobest practical control technology currently achievablerdquo (BPT) which is the minimum level of control required by section 301(b)(1)(A) of the Clean Water Act
In many cases BPT BCT and BAT limitations are based on effluent guidelines developed by EPA for specific industries On December 3 1982 EPA published effluent guidelines for the mining industry These guidelines are found in 40 CFR 440 Effluent guidelines applicable to molybdenum mines such as the TCM are found in the Copper Lead Zinc Gold Silver and Molybdenum Ores Subcategory (Subpart J) of Part 440 The BAT(40 CFR 440103) and BPT (40 CFR 440102) effluent limitation guidelines that apply to the TCM discharges are shown in the following table
C-1
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 27: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/27.jpg)
TABLE C-1 Technology-Based Effluent Limitations for the TCM
Effluent Characteristic
Effluent Limitations for Mine Drainage (outfalls 001 and 002)
Effluent Limitations for Mill Process Waters (outfalls 004 and 005)
daily maximum monthly average daily maximum monthly average
cadmium ugl 100 50 100 50
copper ugl 300 150 300 150
lead ugl 600 300 600 300
mercury ugl 2 1 2 1
zinc ugl 1500 750 1000 500
TSS mgl 30 20 30 20
pH su within the range 60 -90 within the range 60 - 90
III Water Quality-based Evaluation
In addition to the technology-based limits discussed above EPA evaluated the TCMCrsquos discharges to determine compliance with Section 301(b)(1)(C) of the CWA This section requires the establishment of limitations in permits necessary to meet water quality standards by July 1 1977
The regulations at 40 CFR 12244(d) implement section 301(b)(1)(C) of the CWA These regulations require that permits include limits for all pollutants or parameters which ldquoare or may be discharged at a level which will cause have the reasonable potential to cause or contribute to an excursion above any state water quality standard including state narrative criteria for water qualityrdquo The limits must be stringent enough to ensure that water quality standards are met and must be consistent with any available wasteload allocation (WLA)
In determining whether water quality-based limits are needed and developing those limits when necessary EPA follows guidance in the Technical Support Document for Water Quality-based Toxics Control (TSD EPA 1991) The water quality-based analysis consists of four steps
1 Determine the appropriate water quality criteria (see Section IIIA below) 2 Determine if there is ldquoreasonable potentialrdquo for the discharge to exceed the criteria in
the receiving water (see Section IIIB) 3 If there is ldquoreasonable potentialrdquo develop a WLA (see Section IIIC) 4 Develop effluent limitations based on the WLA (see Section IIIC)
The following sections provide a detailed discussion of each step Appendix D provides an example calculation to illustrate how these steps are implemented
C-2
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 28: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/28.jpg)
A Water Quality Criteria
The first step in developing water quality-based limits is to determine the applicable water quality criteria For Idaho the State water quality standards are found at IDAPA 16 Title 1 Chapter 2 (IDAPA 160102) The applicable criteria are determined based on the beneficial uses of the receiving water As discussed in Section IV of the Fact Sheet the beneficial uses for the receiving waters of the Thompson Creek Mine discharges are as follows
Thompson Creek (outfalls 001 and 002) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001e)
Squaw Creek (Outfall 004) - agricultural water supply cold water biota salmonid spawning secondary contact recreation (IDAPA 16010213001f)
Salmon River (Outfall 005) - domestic water supply agricultural water supply cold water biota salmonid spawning primary contact recreation secondary contact recreation special resource water (IDAPA 16010213001a)
For any given pollutant different uses may have different criteria To protect all beneficial uses the permit limits are based on the most stringent of the water quality criteria applicable to those uses The applicable criteria based on the above uses are summarized in Tables C-2 through Cshy4
Idahorsquos aquatic life criteria for several of the metals of concern are calculated as a function of hardness measured in mgl of calcium carbonate (CaCO3) As the hardness of the receiving water increases the toxicity decreases and the numerical value of the criteria decreases The hardness used to calculate the criteria was the hardness in the receiving water after mixing with the effluent For the existing outfalls (001 and 002) the actual hardness measured downstream of each outfall was used to calculate the hardness-based criteria For the new outfalls (004 and 005) the hardness was calculated based on a flow-proportioned mix of the expected effluent hardness and existing receiving water hardness The equations used to derive criteria that are based on hardness are shown in Table C-3 The numerical values of the hardness-based criteria for each outfall is provided in Table C-4 The footnotes of Table C-4 provide more details on how hardness was derived for each outfall
In addition to the calculation for hardness Idahorsquos criteria for some metals include a ldquoconversion factorrdquo to convert from total recoverable to dissolved criteria Conversion factors address the relationship between the total amount of metal in the water column (total recoverable metal) and the fraction of that metal that causes toxicity (bioavailable metal) Conversion factors for most of the dissolved criteria are shown in Table C-3
C-3
Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
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Table C-2 Water Quality Criteria Applicable to TCMC Discharges1
Parameter microgl unless otherwise noted
Cold Water Biota - Aquatic Life Criteria2 Human Health Criteria
Acute Criteria Chronic Criteria Domestic Water Supply Criteria
(consumption of water amp organisms)3
Primary and Secondary Contact Recreation
Criteria (consumption of organisms)4
Antimony NA NA 14 NA
Arsenic 360 190 50 50
Cadmium see Table C-4 see Table C-4 NA NA
Chromium III see Table C-4 see Table C-4 NA NA
Chromium VI 16 11 NA NA
Copper see Table C-4 see Table C-4 NA NA
Lead see Table C-4 see Table C-4 NA NA
Mercury 21 0012 014 015
Nickel see Table-4 see Table C-4 610 4600
Selenium 20 5 NA NA
Silver see Table C-4 NA NA NA
Zinc see Table C-4 see Table C-4 NA NA
pH (su) within the range of 65 - 95 NA NA
Turbidity (NTU) below mixing zone shall not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for more than 10 days
NA NA
WET (TU) surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses5
Footnotes 1 - Per IDAPA 16010225003b water quality criteria for agricultural water supplies will generally be satisfied by the water quality criteria set forth in Section 200 (surface waters shall be free from toxic substances in concentrations that impair designated beneficial uses) 2 - The aquatic life criteria are based on IDAPA 16010225002 This section cites the National Toxics Rule (NTR) 40 CFR 13136(b)(1) and the NTR subparts for toxics (metals) The aquatic life criteria for arsenic cadmium chromium copper lead mercury (acute only) nickel silver and zinc are expressed as the dissolved fraction of the metal The aquatic life criteria for cadmium chromium III copper lead nickel silver and zinc are calculated as a function of hardness per the equations shown in Table C-3 See Table C-4 for the numerical values 3 - The domestic water supply criteria are based on IDAPA 16010225003a which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) These criteria are applicable to the Salmon River 4 - The recreation criteria are based on IDAPA 16010225001 which cites the NTR (except for arsenic which is specified as 50 ugl in the Idaho standards) 5 - EPArsquos recommended magnitudes for this narrative criterion are 1 TUc and 03 TUa for the chronic and acute criteria respectively (TSD 1991) TU means toxicity units where TUc is equal to the reciprocal of the effluent concentration that causes no observable effect in a chronic toxicity test and TUa is the reciprocal of the effluent concentration that causes 50 mortality in an acute toxicity test
C-4
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 30: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/30.jpg)
Table C- 3 Hardness-Based Water Quality Criteria Equations
Parameter dissolved criterion = conversion factor x total criterion
(H = hardness)
conversion factor total criterion
Cadmium acute 1136672 - (0041838)lnH exp [(1128(lnH) - 3828]
chronic 1101672 - (0041838)lnH exp [(07852)lnH - 3490]
Chromium III
acute 0316 exp [(0818)lnH + 3688]
chronic 086 exp [(0818)lnH + 1561]
Copper acute 0960 exp [(09422)lnH - 1464]
chronic 0960 exp [(08545)lnH -1465]
Lead acute 146203 - (0145712)lnH exp [(1273)lnH - 1460]
chronic 146203 - (0145712)lnH exp [(1273)lnH - 4705]
Nickel acute 0998 exp [0846(lnH) + 33612]
chronic 0997 exp [0846(lnH) + 11645]
Silver acute 085 exp [172(lnH) - 652]
Zinc acute 0978 exp [08473(lnH) + 08604]
chronic 0986 exp [08473(lnH) + 07614]
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Cadmium acute 31 19 34 26 15 24 089
chronic 091 066 098 081 23 077 039
Chromium III
acute 480 340 520 420 1300 400 190
chronic 160 110 170 140 430 130 61
Copper acute 15 97 16 12 46 12 50
chronic 99 68 11 86 28 81 37
Lead acute 54 33 60 45 200 42 15
C-5
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 31: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/31.jpg)
Table C-4 Hardness-Based Water Quality Criteria Applicable to TCMC Discharges
Parameter ugl dissolved
Outfall 001 based on Thompson Creek flow (see note)
Outfall 002 based on Thompson Creek flow (see note)
Outfall 004 based on Squaw Creek
flow (see note)
Outfall 005 (see note)
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
chronic 21 13 23 18 78 16 059
Nickel acute 1200 850 1300 1100 3500 1000 470
chronic 140 95 150 120 390 110 52
Silver acute 26 12 30 20 22 17 036
Zinc acute 100 69 110 87 280 82 38
chronic 91 63 98 79 260 74 34
Note The hardness value used is the hardness measured or calculated after the effluent is mixed with the receiving water The data used to determine hardness was based on the last five years of data Only the last five years was used as it is most representative of current and future conditions Hardness for each outfall was determined as described below
Outfall 001 Hardness values of 85 mgl CaCO3 and 55 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-3 (downstream of Outfall 001) during these flow regimes over the last five years
Outfall 002 Hardness values of 93 mgl CaCO3 and 72 mgl CaCO3 were used for Thompson Creek flows of lt 7 cfs and $ 7 cfs respectively These values represent the 5th percentile of the hardness values measured at TC-1 (downstream of Outfall 002) during these flow regimes over the last five years
Outfall 004 A hardness value of 290 mgl CaCO3 was used for Squaw Creek flows of lt 50 cfs A hardness of 67 mgl CaCO3 was used for Squaw Creek flows of $50 cfs These values represent the mixed effluent and receiving water hardness calculated using a mass balance equation (similar to Equation 1 presented in Section B below) The following values were used in the mass balance equation - effluent flow and hardness a hardness of 912 mgl for the effluent (based on the flow proportioned 5th percentile hardness values of wastewaters from the LA and PBS over the last five years) - effluent flow the maximum flow for Outfall 004 was used - receiving water hardness 110 mgl and 45 mgl for Squaw Creek flows of lt 50 cfs and $50 cfs respectively (these are the 5th percentile of the hardness values measured at SQ-2 downstream of proposed Outfall 004 at these flow tiers) The downstream location was used to take into account the contribution from Bruno Creek and Outfall 003 - receiving water flows the 7Q10 Squaw Creek flow for the lt50 cfs tier and 50 cfs for the $50 cfs flow tier
Outfall 005 A hardness of 27 mgl CaCO3 was used It represents the mixed effluent and receiving water hardness calculated using a mass balance equation (see Equation 1) The following values were used in the mass balance equation - effluent hardness Since Outfall 005 may include wastewaters from 001 and 002 as well as or instead of the LA PBS and PIT wastewaters the 5th percentile hardness of each of these sources was calculated and the minimum 5th percentile hardness value was used This resulted in an effluent hardness of 190 mgl (the 5th
percentile hardness of Outfall 002) - effluent flow the maximum flow for Outfall 005 - receiving water hardness a hardness of 25 mgl for the receiving water (it represents the 5th percentile of the hardness values measured at SR-3 upstream of proposed Outfall 005) - receiving water flow the 7Q10 flow of the Salmon River
C-6
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 32: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/32.jpg)
B Reasonable Potential Evaluation
To determine if there is ldquoreasonable potentialrdquo to cause or contribute to an exceedence of water quality criteria for a given pollutant (and therefore whether a water quality-based effluent limit is needed) for each pollutant present in a discharge EPA compares the maximum projected receiving water concentration to the criteria for that pollutant If the projected receiving water concentration exceeds the criteria there is ldquoreasonable potentialrdquo and a limit must be included in the permit EPA uses the recommendations in Chapter 3 of the TSD to conduct this ldquoreasonable potentialrdquo analysis This section discusses how reasonable potential is evaluated
The maximum projected receiving water concentration is determined using the following mass balance equation
Cd x Qd = (Ce x Qe) + (Cu x Qu)
where Cd = receiving water concentration downstream of the effluent discharge (concentration at the edge of the mixing zone)
Ce = maximum projected effluent concentration Cu = receiving water upstream concentration of pollutant Qe = effluent flow Qu = receiving water upstream flow Qd = receiving water flow downstream of the effluent discharge = (Qe + Qu)
If a mixing zone is allowed and solving for Cd the mass balance equation becomes
Cd = (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 1) Qe + (Qu x MZ)
where MZ = the percent mixing zone based on receiving water flow
Where no mixing zone is allowed Cd = Ce (Equation 2)
For some of the metals of concern the aquatic life water quality criteria are expressed as dissolved (see Table C-2 footnote 2) Yet effluent concentrations and NPDES permit limits are expressed as total recoverable metals The dissolved metal is the concentration of an analyte that will pass through a 045 micron filter Total metal is the concentration of an analyte in an unfiltered sample To account for the difference between total effluent concentrations and dissolved criteria ldquotranslatorsrdquo are used in the reasonable potential (and permit limit derivation) equations Translators can either be site-specific numbers or default numbers EPA guidance related to the use of translators in NPDES permits is found in The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96shy007 June 1996) In the absence of site-specific translators this guidance recommends the use of the water quality criteria conversion factors (see Table C-3) as the default translators Because
C-7
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 33: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/33.jpg)
site-specific translators were not available the conversion factors were used as default translators in the reasonable potential and permit calculations for the TCMC discharges Therefore for those metals with criteria expressed as dissolved Equations 1 and 2 become
where a mixing zone is allowed
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
where no mixing zone is allowed Cd = translator x Ce (Equation 4)
After Cd is determined it is compared to the applicable water quality criterion If it is greater than the criterion a water quality-based effluent limit is developed for that parameter The following discusses each of the factors used in the mass balance equation to calculate Cd
Ce (maximum projected effluent concentration) Per the TSD the maximum projected effluent concentration in the mass balance equation is represented by the 99th percentile of the effluent data The 99th percentile is calculated using the statistical approach recommended in the TSD ie by multiplying the maximum reported effluent concentration by a reasonable potential multiplier (RPM)
Ce = (maximum measured effluent concentration) x RPM (Equation 5)
The RPM accounts for uncertainty in the effluent data The RPM depends upon the amount of effluent data and variability of the data as measured by the coefficient of variation (CV) of the data The RPM decreases as the number of data points increases and the variability (CV) of the data decreases When there are not enough data to reliably determine a CV the TSD recommends using 06 as a default value Once the CV of the data is determined the RPM is determined using the statistical methodology discussed in Section 33 of the TSD
Maximum reported effluent concentrations CVs and RPMs used in the reasonable potential calculations were based on data collected by TCMC (DMR data and other monitoring) and EPA (compliance inspection data) since January 1994 Only the last five years of data was used since it was determined to be most representative of current and future conditions See Tables C-8 through C-11 for a summary of the maximum reported effluent concentrations CVs and RPMs used in the reasonable potential analysis
Cu (upstream concentration of pollutant) The ambient concentration in the mass balance equation is based on a reasonable worst-case estimate of the pollutant concentration upstream from the discharge point Where sufficient data exists the 95th percentile of the ambient data is generally used as an estimate of worst-case
C-8
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 34: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/34.jpg)
TCMC has been monitoring the receiving waters since the beginning of mine operations EPA reviewed the ambient data collected by TCMC to calculate Cu Two difficulties were encountered in evaluating the ambient data First much of the data was reported as non-detect and in some cases the detection limits exceeded the water quality criteria Second most of the metals data was reported as total whereas for some metals the aquatic life water quality criteria are expressed as dissolved In the most recent rounds of ambient monitoring (1998 and 1999) TCMC analyzed for both total and dissolved metals and reported lower detection limits Therefore only this most recent data was used to determine background concentrations Since only two to six data points were available for each parameter the maximum value detected (instead of the 95th percentile) was used as Cu Where all the values were less than the low detection limits zero was assumed
The Cursquos used for each outfall and the ambient monitoring stations used to determine Cu are identified in Tables C-8 through C-11 (see Figure A-2 for monitoring station locations)
Qu (upstream flow) The upstream flow used in the mass balance equation depends upon the criterion that is being evaluated The critical low flows used to evaluate compliance with the water quality criteria are
- The 1-day 10-year low flow (1Q10) is used for the protection of aquatic life from acute effects It represents the lowest daily flow that is expected to occur once in 10 years
- The 7-day 10-year low flow (7Q10) is used for protection of aquatic life from chronic effects It represents the lowest 7-day average flow expected to occur once in 10 years
- The 30-day 5-year low flow (30Q5) is used for the protection of human health and agricultural uses from non-carcinogens It represents the 30-day average flow expected to occur once in 5 years
- The harmonic mean flow is a long-term average flow and is used for the protection of human health and agricultural uses from carcinogens It is the number of daily flow measurements divided by the sum of the reciprocals of the flows
Data collected from United States Geological Survey (USGS) stations on Squaw Creek Thompson Creek and the Salmon River were used to estimate the critical low flows applicable to each outfall Table C-5 below provides this information
Thompson Creek and Squaw Creek flows vary dramatically with precipitation and snow melt with peak flows occurring in May through July Therefore two sets of effluent limits were developed for outfalls 001 002 and 004 representative of both high and low flow conditions and the reasonable potential analysis for these outfalls was conducted for both flow conditions Flows representative of critical low flow conditions are those provided in Table C-5 Based on a hydrologic analysis conducted by TCMC receiving water flows used for the high flow
C-9
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 35: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/35.jpg)
conditions are 7 cfs for Thompson Creek and 50 cfs for Squaw Creek (TCMC 1999) These flows approximate the lowest receiving flows recorded during the peak flow months
Table C-5 Receiving Water Flow Data
Flow Information Thompson Creek Squaw Creek Salmon River1
USGS Station 13297330 13297355 13296500
period of record 1973 - 1995 1973 - 1995 1922 - 1991
1Q10 cfs 158 406 295
7Q10 cfs 205 456 323
30Q5 cfs 264 583 390
harmonic mean (HM) cfs 575 1232 686
footnote 1 - The Salmon River gauge is located below the confluence with the Yankee Fork Flows from this gauge were multiplied by the drainage basin ratio between the gauge and the diffuser location to obtain the Salmon River flows at the diffuser location shown in this table (IDEQ 2000)
Qe (effluent flow) The effluent flow used in the mass balance equation is the maximum effluent flow Because the effluent flows from outfalls 001 and 002 exhibit dramatic seasonal variations separate effluent flows were determined for both high and low receiving water flows The effluent flows used and how they were determined are shown in the following table
Table C-6 Effluent Flows
Outfall Receiving Water Flow Tier
Effluent Flow (Qe)
Basis
001 lt 7 cfs 0023 cfs critical dilution ratio = 0011 (see footnote 1) therefore Qe = 0011 x Qu = 0011 x 205 cfs = 0023 cfs
$ 7 cfs 0645 cfs critical dilution ratio = 00922 (see footnote 1) therefore Qe = 00922 x Qu = 00922 x 7 cfs
002 lt 7 cfs 0175 cfs critical dilution ratio = 00852 (see footnote 1) therefore Qe = 00852 x Qu = 00852 x 205 cfs
$ 7 cfs 125 cfs critical dilution ratio = 0179 (see footnote 1) therefore Qe = 0179 x Qu = 0179 x 7 cfs
004 both flow tiers 13 cfs maximum flows of LA and PBS waste waters as monitored by TCMC over the last three years
005 no flow tiers 27 cfs maximum flow of LA PBS and PIT waste waters as monitored by TCMC over the last three years and diffuser design flow
C-10
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 36: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/36.jpg)
Table C-6 Effluent Flows
Footnote 1- Because the effluent flow varies dramatically and the variations are similar to the receiving water flow variations the effluent flows for outfalls 001 and 002 were calculated based on the ratio of the effluent flow to upstream receiving water flow (dilution ratio) for each flow tier Dilution ratios were determined based on daily flow monitoring of the outfalls and Thompson Creek since the outfalls began discharging (since 1983) Critical dilution ratios were calculated by IDEQ as the highest ratio expected to occur in a 4-day period once every 4 years which corresponds to the biologically based water quality criteria (IDEQ 2000) For the Thompson Creek data set this corresponds to the 996th-percentile of the dilution ratios
MZ (the percent mixing zone based on receiving water flow) Mixing zones are defined as a limited area or volume of water where the discharge plume is progressively diluted by the receiving water Water quality criteria may be exceeded in the mixing zone as long as acutely toxic conditions are prevented from occurring and the applicable existing designated uses of the water body are not impaired as a result of the mixing zone Mixing zones are allowed at the discretion of the State based on the State waster quality standards regulations
The Idaho water quality standards at IDAPA 160102060 allow for the use of mixing zones after a biological chemical and physical appraisal of the receiving water and the discharge The standards allow water quality within a mixing zone to exceed chronic water quality criteria so long as chronic water quality criteria are met at the boundary of the mixing zone Acute water quality criteria may be exceeded within a zone of initial dilution inside the chronic mixing zone In accordance with state water quality standards only IDEQ may authorize mixing zones As discussed in Section VIIIB of the Fact Sheet IDEQ has prepared a preliminary CWA Section 401 Certification authorizing mixing zones for the TCM discharges The mixing zone volumes are shown in Table C-7 More information on the mixing zones (including the biological chemical and physical appraisal) is available in IDEQrsquos preliminary certification (IDEQ 2000)
If IDEQ authorizes a different size mixing zone in its final 401 certification EPA will recalculate the reasonable potential and effluent limits based on the final mixing zones If the State does not authorize a mixing zone in its 401 certification EPA will recalculate the limits based on meeting water quality criteria at the point of discharge (ie ldquoend-of-piperdquo limits)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Arsenic 25 25 25 25 25 25 25
Cadmium 25 50 50 50 50 50 25
Chromium 25 25 25 25 50 25 25
Copper 25 20 25 125 0 25 25
Lead 25 667 50 50 25 25 25
C-11
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 37: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/37.jpg)
Table C-7 Mixing Zones For The TCM Discharges For Aquatic Life Water Quality Criteria1
(expressed as percent of receiving water flow)
Parameter Outfall 001 Outfall 002 Outfall 004 Outfall 005
lt 7 cfs $ 7 cfs lt 7 cfs $ 7 cfs lt 50 cfs $ 50 cfs
Mercury 25 25 25 25 25 25 25
Nickel 25 25 25 25 25 25 25
Selenium 25 50 25 40 50 25 25
Silver 25 25 25 25 25 25 25
Zinc 25 20 25 40 0 25 25
footnote 1 - The Idaho standards are silent regarding mixing zones for human health criteria EPA uses 100 of the receiving water for dilution for human health criteria since the mixing zone size limitation for aquatic life is to account for fish passage
Reasonable Potential Summary A summary of the data used to determine reasonable potential for each outfall is provided in Tables C-8 through C-11 Results of the reasonable potential analysis for each outfall is provided in Tables C-12 through C-15 Based on the reasonable potential analysis water quality-based effluent limits were developed for the following parameters
- Outfall 001 cadmium copper lead mercury selenium and zinc (at $ 7 cfs only) - Outfall 002 cadmium copper lead mercury selenium and zinc - Outfall 004 cadmium chromium (at lt 50 cfs only) copper lead mercury silver (at $ 50 cfs only) and zinc - Outfall 005 cadmium copper lead mercury silver and zinc
To demonstrate the reasonable potential analysis an example of the reasonable potential determination for cadmium in Outfall 001 is provided in Appendix D (see Steps 1 and 2)
C Water Quality-Based Permit Limit Derivation
Once EPA has determined that a water quality-based limit is required for a pollutant the first step in developing the permit limit is development of a wasteload allocation (WLA) for the pollutant A WLA is the concentration (or loading) of a pollutant that the permittee may discharge without causing or contributing to an exceedence of water quality standards in the receiving water WLAs and permit limits are derived based on guidance in the TSD WLAs for this permit were established in two ways based on a mixing zone (for most metals) and based on meeting water quality criteria at ldquoend-of-piperdquo (for pH and for copper and zinc in Outfall 004 at low flow since no mixing zone was authorized)
C-12
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 38: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/38.jpg)
The WLAs are then converted to long-term average concentrations (LTAs) and compared The most stringent LTA concentration for each parameter is converted to effluent limits This section describes each of these steps
Calculation of WLAs Where the state authorizes a mixing zone for the discharge the WLA is calculated as a mass balance based on the available dilution background concentration of the pollutant and the water quality criterion WLAs are calculated using the same mass balance equation used in the reasonable potential evaluation (see Equation 1) However Cd becomes the criterion and Ce the WLA Making these substitutions Equation 1 is rearranged to solve for the WLA becoming
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 6) Qe
As discussed previously the aquatic life criteria for some metals is expressed as dissolved However the NPDES regulations require that metals limits be based on total recoverable metals (40 CFR 12245(c)) This is because changes in water chemistry as the effluent and receiving water mix could cause some of the particulate metal in the effluent to dissolve Therefore a translator is used in the WLA equation to convert the dissolved criteria to total The translator is the same translator discussed in the reasonable potential evaluation in the previous section (the criteria conversion factors are used as the default translators) For criteria expressed as dissolved a translator is added to Equation 6 and the WLA is calculated as
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
Where no mixing zone is allowed the criterion becomes the WLA (see Equations 8 and 9) Establishing the criterion as the WLA ensures that the permittee does not contribute to an exceedence of the criteria
no mixing zone WLA = criterion (Equation 8)
WLA = criteriontranslator (for criteria expressed as dissolved) (Equation 9)
WLAs for the parameters that exhibited reasonable potential for each outfall are provided in Tables C-16 through C-22 at the end of this appendix Appendix D (see Step 3) provides an example of how the WLAs for cadmium in Outfall 001 were developed
Calculation of Long-term Average Concentrations (LTAs) As discussed above WLAs are calculated for each parameter for each criterion Because the different criteria (acute aquatic life chronic aquatic life human health) apply over different time frames and may have different mixing zones it is not possible to compare the criteria or the WLAs directly to determine which criterion results in the most stringent limits For example the acute criteria are applied as a oneshy
C-13
hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
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hour average and may have a smaller (or no) mixing zone while the chronic criteria are applied as a four-day average and may have a larger mixing zone
To allow for comparison the acute and chronic aquatic life criteria are statistically converted to long-term average (LTA) concentrations This conversion is dependent upon the coefficient of variation (CV) of the effluent data and the probability basis used The probability basis corresponds to the percentile of the estimated concentration EPA uses a 99th percentile for calculating a long-term average as recommended in the TSD The following equation from Chapter 5 of the TSD is used to calculate the LTA concentrations (alternately Table 5-1 of the TSD may be used)
LTA = WLA x exp[05Fsup2 - zF] (Equation 10)
where Fsup2 = ln(CVsup2 + 1) for acute aquatic life criteria = ln(CVsup24 + 1) for chronic aquatic life criteria
CV = coefficient of variation z = 2326 for 99th percentile probability basis per the TSD
Calculation of Effluent Limits The LTA concentration is calculated for each criterion and compared The most stringent LTA concentration is then used to develop the maximum daily (MDL) and monthly average (AML) permit limits The MDL is based on the CV of the data and the probability basis while the AML is dependent upon these two variables and the monitoring frequency As recommended in the TSD EPA used a probability basis of 95 percent for the AML calculation and 99 percent for the MDL calculation The MDL and AML are calculated using the following equations from the TSD (alternately Table 5-2 of the TSD may be used)
MDL or AML = LTA x exp[zF-05Fsup2] (Equation 11)
for the MDL Fsup2 = ln(CVsup2 + 1) z = 2326 for 99th percentile probability basis per the TSD
for the AML Fsup2 = ln(CVsup2n + 1) n = number of sampling events required per month z = 1645 for 95th percentile probability basis per the TSD
For setting water quality-based limits for protection of human health uses the TSD recommends setting the AML equal to the WLA and then calculating the MDL (ie no calculation of LTAs) The human health MDL is calculated based on the ratio of the AML and MDL as expressed by Equation 11 The MDL therefore is based on effluent variability and the number of samples per month AMLMDL ratios are provided in Table 5-3 of the TSD
The water quality-based effluent limits developed for each outfall for each parameter that exhibited reasonable potential are shown in Tables C-16 through C-22 These tables also show intermediate calculations (ie WLAs LTAs) used to derive the effluent limits Appendix D
C-14
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 40: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/40.jpg)
shows an example of the permit limit calculation for cadmium in Outfall 001 (see Steps 3 and 4)
IV Summary of Draft Permit Effluent Limitations and WET Triggers
A Summary of Draft Permit Effluent Limitations
As discussed in Section I of this appendix technology-based limits were applied to each discharge and evaluated (via the reasonable potential evaluation discussed in Section III) to determine whether these limits may result in any exceedences of water quality standards in the receiving water If exceedences could occur then water quality-based effluent limits were developed The following summarizes the final proposed effluent limits developed for each outfall
Metals The technology-based effluent limits applicable to TCMCrsquos discharges were presented in Table C-1 The water-quality based effluent limits for metals applicable to the discharges are shown in Tables C-16 through C-22 The zinc limit for Outfall 001 during low flow conditions is technology-based All of the other metals limits were based on water quality-standards
TSS The State does not have a water quality standard for TSS Therefore the TSS limits included in the draft permit are the technology-based limits shown in Table C-1
pH The State water quality standard for pH is 65 - 95 standard units for the protection of aquatic life (see Table C-2) The technology-based effluent limits specify a pH of 60 - 90 (see Table C-1) The draft permit incorporates the more stringent water quality-based minimum of 65 and the technology-based maximum of 90 standard units
mass-based limits The effluent limitations thus far have been expressed in terms of concentration However with a few exceptions the NPDES regulations (40 CFR 12245(f)) require that effluent limits also be expressed in terms of mass The following equation is used to convert the concentration-based limits into mass-based limits
mass limit (lbday) = concentration limit (ugl) x effluent flow rate x conversion factor (Equation 12)
where conversion factor = 0005379 (to convert units on the right side of the equation to lbday) effluent flow rate = maximum discharge rate in cfs (see Table C-6)
The above equation was used to calculate mass-based limits for outfalls 004 and 005 where the maximum effluent flow was used to calculate the effluent limits (per the TSD the flows used to calculate mass-based limits should be consistent with those used to develop the WLAs) Mass-based limits for these outfalls are shown in Tables 4 and 5 of the Fact Sheet
However for outfalls 001 and 002 the effluent limits were based on a dilution ratio (since the effluent flows vary dramatically and vary with receiving water flow) Therefore mass loading
C-15
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 41: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/41.jpg)
will be controlled for these outfalls via the dilution ratio used to develop the effluent limits The draft permit requires that the dilution ratios shown in Table C-6 not be exceeded
B Whole Effluent Toxicity (WET) Triggers
As discussed in Section VIB of the fact sheet there was not an adequate amount of WET data to determine the need for effluent limits in the draft permit The draft permit includes WET monitoring and establishes trigger levels for each outfall that if exceeded would trigger additional WET testing and potentially investigations to reduce toxicity The trigger levels were calculated based on the WET criteria receiving water flow effluent flow and available dilution The trigger levels were calculated using the following mass-balance equation (this is basically the same as Equation 6)
WET toxicity trigger = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 13) Qe
where criterion = 1 TUc for compliance with the chronic criterion (see Table C-2) Qe = effluent flow (see Table C-6) Qu = upstream flow (see page C-9 and Table C-5) Cu = upstream concentration = 0 for WET (assuming no upstream toxicity) MZ = mixing zone = 1 for compliance with chronic criteria (IDEQrsquos preliminary certification stated that chronic WET testing and triggers be based on 100 dilutions)
Solving equation 13 resulted in the chronic trigger values in Table 6 of the draft permit The acute trigger value was set at 1 TUa for all outfalls based on the IDEQ preliminary certification of no acute toxicity with 100 effluent
C-16
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 42: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/42.jpg)
TABLE C- 8 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 001
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Arsenic 2 06 25 21 3 05
Cadmium 100 06 na 1 na 007
Chromium 10 06 22 22 na 0
Copper 300 06 na 1 na 05
Lead 600 06 na 1 na 012
Mercury 2 06 na 1 0 0
Nickel 10 06 22 22 07 07
Selenium 42 05 21 23 1 na
Silver 005 06 22 22 na 0
Zinc 1500 06 na 1 na 5
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) was determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for WET since only two data sets were available
2 - The effluent data is based on sampling of Outfall 001 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA used analyses for these parameters from the Buckskin sediment pond The metals data is expressed as the total form 3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury zinc) the maximum effluent concentration used to determine RP is the technology-based maximum daily limitation (see Table C-1) The technology-based limit is used since water quality-based limits are only required if discharge at the technology-based limits have reasonable potential to exceed water quality standards in the receiving water For other parameters the maximum effluent concentration used is the maximum detected concentration
4- Where the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used This was the case for all parameters except selenium Adequate data was available for selenium to calculate the CV (standard deviation divided by the mean)
5 - For parameters with technology-based effluent limitation guidelines the RPM is 1 For other parameters the RPM is based on the CV and the number of data points (number of samples collected over the last five years)
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-4 upstream of Outfall 001 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background value is based on a high-resolution analysis conducted in December 1999 by a selenium specialty lab
C-17
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 43: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/43.jpg)
TABLE C- 9 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 002
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 24 06 58 16 07 07
Cadmium 100 06 na 1 na 006
Chromium 06 06 23 22 na 07
Copper 300 06 na 1 na 06
Lead 600 06 na 1 na 018
Mercury 2 06 na 1 0 0
Nickel 19 06 23 38 09 09
Selenium 17 06 21 23 2 and 27 na
Zinc 1500 06 na 1 na 30
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns the receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality For example RP was not determined for silver since all the effluent data was reported at less than detection limits
2 - The effluent data is based on sampling of Outfall 002 conducted by TCMC and EPA (compliance inspection data) since 1994 Because limited effluent data existed for chromium nickel selenium and silver EPA also used analyses for these parameters from the Pat Hughes sediment pond The metals data is expressed as the total form
3 - See footnote 3 Table C-8
4- Since the majority of the effluent data was reported at less then detection limits effluent-specific variability cannot be determined so a default CV of 06 was used
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Thompson Creek monitoring location TC-2 upstream of Outfall 002 Except for selenium only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected Where all the data was reported at less than detection limits zero was used as Cu For selenium the background values were calculated by IDEQ based on the background value upstream of Outfall 001 (TC-4 see Table C-8) plus the increase in selenium due to Outfall 001 The calculated background values for selenium were 2 ugl at Thompson Creek flows of lt 7 cfs and 27 ugl at Thompson Creek flows $ 7 cfs (IDEQ 2000)
C-18
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 44: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/44.jpg)
TABLE C- 10 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 004
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration (Cu)
6
Maximum Effluent
Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier (RPM)5 total dissolved
Arsenic 40 06 17 25 08 08
Cadmium 100 06 na 1 na 013
Chromium 40 06 16 25 na 06
Copper 300 06 na 1 na 13
Lead 600 06 na 1 na 068
Mercury 2 06 na 1 0 0
Nickel 40 06 17 25 1 1
Selenium 51 06 17 25 0 na
Silver 92 06 17 25 na 0
Zinc 1000 06 na 1 na 3
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA and PBS waste streams conducted by TCMC since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine reasonable potential is the technology-based maximum daily limitation concentration (see Table C-1) For other parameters the maximum effluent concentration used is the flow-weighted average of the maximum detected concentrations in PBS and LA samples
4- A default CV of 06 is used because the data for this discharge is from different sources (LA and PBS) the exact flow-proportioned combination of which is uncertain (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Squaw Creek monitoring location SQshy2 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
C-19
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 45: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/45.jpg)
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
Parameter1
ugl
Effluent Data2 Receiving Water Upstream Concentration
(Cu)6Maximum
Effluent Concentration3
Coefficient of Variation (CV)4
Number of Samples
Reasonable Potential Multiplier
(RPM)5 total dissolved
Antimony 99 06 6 38 016 na
Arsenic 30 06 9 32 21 19
Cadmium 100 06 na 1 na 016
Chromium 40 06 6 38 na 0
Copper 300 06 na 1 na 1
Lead 600 06 na 1 na 020
Mercury 2 06 na 1 0 0
Nickel 50 06 6 38 11 11
Selenium 42 06 6 23 0 na
Silver 92 06 6 38 na 0
Zinc 1000 06 na 1 na 3
C-20
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 46: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/46.jpg)
TABLE C- 11 Summary of Data Used to Determine Reasonable Potential and Develop Effluent Limits for Outfall 005
na = not applicable used for two situations shynumber of samples column The number of samples is used to develop the RPM For parameters with technology-based effluent limitation guidelines the RPM is 1 therefore the number of samples is not important receiving water concentration columns The receiving water concentrations are only needed for the form in which the criterion is expressed
Footnotes 1 - Reasonable potential (RP) determined only for parameters with an adequate amount of data of adequate quality
2 - The effluent data is based on sampling of the LA PBS and PIT waste streams conducted by TCMC since 1994 Since discharge of effluent from outfalls 001 and 002 through 005 will be allowed the effluent data was also based on sampling from these outfalls since 1994 The metals data is expressed as the total form
3 - For parameters with technology-based effluent limitation guidelines (cadmium copper lead mercury and zinc) the maximum effluent concentration used to determine RP is the technology-based maximum effluent concentration (see Table C-1) For other parameters the maximum effluent concentration used is the maximum of either the flow-weighted average of the maximum detected concentrations in PBS LA and PIT samples or the maximum detected concentration in outfalls 001 and 002
4- A default CV of 06 is used because the data for this discharge is from different sources (LA PBS and PIT) the exact flow-proportioned combination of which is uncertain and potentially from outfalls 001 and 002 (and therefore variability is uncertain)
5 - See footnote 5 Table C-8
6 - The receiving water concentrations are based on samples collected from Salmon River monitoring location SRshy3 Only data from 1998 and 1999 was used since the detection limits from previous sampling events were not adequate to quantify background (detection limits were too high) The concentrations in the table represents the maximum concentration detected (except for lead where the highest concentration was determined to be an outlier) Where all the data was reported at less than detection limits zero was used as Cu
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 070 066 052 no 15 15 081 no
Cadmium 53 40 na yes 15 15 na yes
Chromium1 12 091 na no 58 57 na no
Copper 16 13 na yes 91 91 na yes
C-21
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 47: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/47.jpg)
TABLE C- 12 Summary of Reasonable Potential (RP) Determination for Outfall 001
Lead 27 21 na yes 64 64 na yes
Mercury 0094 0086 0017 yes 046 054 017 yes
Nickel 19 16 088 no 64 64 25 no
Selenium 63 51 na yes 16 16 na yes
Silver 00051 na na no 00025 na na no
Zinc 85 68 na no 470 470 na yes
na = not applicable (no criterion for comparison)
Footnotes
1 - Chromium was assumed to be in the hexavalent form for comparison to the criteria for chromium-VI (the most stringent of the chromium criteria)
2 - The aquatic life maximum projected receiving water concentrations are expressed as dissolved for arsenic cadmium copper lead nickel silver and zinc All other metal concentrations in these columns are expressed as total
3 - Reasonable Potential (RP) exists if the maximum projected receiving water concentration exceeds the criteria (see Tables C-2 and C-4) The maximum projected receiving water concentrations in bold are those that exceed criteria
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
Parameter ugl
RP for Thompson Creek Flows lt 7 cfs RP for Thompson Creek Flows $ 7 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 17 15 079 no 20 20 12 no
Cadmium 17 13 na yes 25 24 na yes
Chromium1 088 085 074 no 095 094 079 no
Copper 89 74 na yes 170 170 na yes
Lead 87 70 na yes 130 130 na yes
Mercury 052 051 012 yes 071 083 030 yes
Nickel 19 17 11 no 23 23 14 no
Selenium 13 11 na yes 14 14 na yes
Zinc 470 400 na yes 470 480 na yes
C-22
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 48: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/48.jpg)
TABLE C- 13 Summary of Reasonable Potential (RP) Determination for Outfall 002
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C- 14 Summary of Reasonable Potential (RP) Determination for Outfall 004
Parameter ugl
RP for Squaw Creek Flows lt 50 cfs RP for Squaw Creek Flows $ 50 cfs
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)
Maximum Projected Receiving Water Concentration (Cd)
2 RP3
(yes or no)aquatic
life acute aquatic life chronic
recreation aquatic life acute
aquatic life chronic
recreation
Arsenic 60 57 17 no 17 17 10 no
Cadmium 35 31 na yes 48 46 na yes
Chromium1 39 35 na yes 98 96 na no
Copper 290 290 na yes 28 28 na yes
Lead 220 200 na yes 49 49 na yes
Mercury 096 11 037 yes 016 019 00051 yes
Nickel 57 54 19 no 10 10 35 no
Selenium 50 46 na no 12 12 na no
Silver 11 na na no 18 na na yes
Zinc 978 986 na yes 95 96 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Parameter Maximum Projected Receiving Water Concentration (Cd)2 ugl Reasonable Potential3
(yes or no) aquatic life acute aquatic life chronic domestic or recreation
Antimony na na 042 no
Arsenic 52 49 23 no
Cadmium 37 33 na yes
Chromium1 53 47 na no
Copper 11 10 na yes
Lead 21 19 na yes
Mercury 0060 0065 0014 yes
Nickel 78 72 24 no
Selenium 34 31 na no
Silver 11 na na yes
C-23
TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
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TABLE C-15 Summary of Reasonable Potential Determination for Outfall 005
Zinc 55 51 na yes
na = not applicable (no criterion for comparison) footnotes Same as Table C-12 footnotes
TABLE C-16 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 580 214 186 113 na na chronic 35 24
Copper 267 228 859 120 na na acute 270 180
Lead 1200 569 387 300 na na chronic 94 64
Mercury 436 0279 140 0147 174 253 chronic 046 032
Selenium 346 941 129 547 na na chronic 150 110
Zinc no RP no RP no RP no RP na na tech 1500 750
na = not applicable (no criterion for comparison) no RP = no reasonable potential to exceed water quality criteria therefore water quality-based limits not developed
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-12) or have technology-based limits (see Table C-1) 2- Effluent limits based on the most stringent aquatic life criteria (lowest LTA) were compared to limits based on recreational use and technology-based limits (see Table C-1) The most stringent of these represents the final effluent limits
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 122 413 392 218 na na chronic 68 47
Copper 309 214 991 113 na na acute 31 21
Lead 313 113 101 594 na na chronic 19 13
Mercury 891 00446 286 00235 178 259 chronic 0073 0050
Selenium 123 267 459 155 na na chronic 42 30
C-24
TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
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TABLE C-17 Summary of Permit Limit Derivation for Outfall 001 at Thompson Creek Flow $$ 7 cfs
Zinc 212 191 682 101 na na acute 210 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-16 footnotes
TABLE C-18 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow lt 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 196 696 631 367 na na chronic 11 78
Copper 525 418 169 221 na na acute 53 36
Lead 409 186 131 980 na na chronic 31 21
Mercury 782 00471 251 00249 241 352 chronic 0077 0053
Selenium 606 138 195 727 na na chronic 23 16
Zinc 289 302 929 160 na na acute 290 200
na = not applicable (no criterion for comparison)
Footnotes 1 - Parameters which exhibited reasonable potential (see Table C-13) 2 - See footnote 2 Table C-16
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 101 315 325 166 na na chronic 52 35
Copper 217 147 696 778 na na acute 22 15
Lead 204 736 654 388 na na chronic 12 83
C-25
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 51: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/51.jpg)
TABLE C-19 Summary of Permit Limit Derivation for Outfall 002 at Thompson Creek Flow $$ 7 cfs
Mercury 576 00288 185 00152 099 144 chronic 0047 0032
Selenium 588 102 189 535 na na chronic 17 11
Zinc 218 192 701 101 na na acute 220 150
na = not applicable (no criterion for comparison) footnotes Same as Table C-18 footnotes
TABLE C-20 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of lt 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 333 708 107 374 na na chronic 12 58
Chromium 400 292 129 154 na na acute 40 20
Copper 483 294 155 155 na na acute amp chronic
48 24
Lead 563 222 181 117 na na chronic 37 18
Mercury 427 00225 137 00119 0823 165 chronic 0037 0018
Zinc 288 261 926 138 na na acute 290 140
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-14) 2 - See footnote 2 Table C-16
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Recreational Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 493 155 158 818 na na chronic 26 13
C-26
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 52: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/52.jpg)
TABLE C-21 Summary of Permit Limit Derivation for Outfall 004 for Squaw Creek Flows of $$ 50 cfs
Copper 116 761 372 401 na na acute 120 58
Lead 513 126 165 664 na na chronic 21 10
Mercury 255 0127 818 0672 592 119 chronic 021 010
Silver 216 na 695 na na na acute 22 11
Zinc 855 772 275 407 na na acute 860 430
na = not applicable (no criterion for comparison) footnotes Same as Table C-20 footnotes
TABLE C- 22 Summary of Permit Limit Derivation for Outfall 005
Parameter1
ugl Aquatic Life Criteria Wasteload Allocations (WLA)
Aquatic Life Criteria Long Term Average (LTA) Concentration
Limits Based on Domestic Use or Recreational Use Criteria
Effluent Limits
acute WLA
chronic WLA
acute LTA
chronic LTA
WLA = AML
MDL Basis2 maximum daily limit
(MDL)
average monthly
limit (AML)
Cadmium 210 757 674 400 na na chronic 12 62
Copper 118 882 378 465 na na acute 120 59
Lead 431 125 138 658 na na chronic 21 10
Mercury 680 0371 218 0196 218 438 chronic 061 030
Silver 121 na 388 na na na acute 12 60
Zinc 1010 989 342 522 na na acute 1000 500
na = not applicable (no criterion for comparison)
Footnotes 1- Parameters which exhibited reasonable potential (see Table C-15) 2- See footnote 2 Table C-16
APPENDIX D -EXAMPLE WATER QUALITY-BASED EFFLUENT LIMIT CALCULATION
This appendix demonstrates how the water quality- based analysis (reasonable potential determination and development of effluent limits) that was described in Section III of Appendix C was performed using cadmium in Outfall 001 as an example
D-1
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 53: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/53.jpg)
Step 1 Determine the applicable water quality criteria
Applicable water quality criteria for cadmium in Outfall 001 are proved in Tables C-2 and C-4 The cadmium criteria applicable to the low flow tier (lt 7 cfs in Thompson Creek) are (see Table C-4)
aquatic life acute = 31 ugl (expressed as dissolved) aquatic life chronic = 091 ugl (expressed as dissolved)
The cadmium criteria applicable to high flow tier ($7 cfs in Thompson Creek) are (Table C-4)
aquatic life acute = 19 ugl (expressed as dissolved) aquatic life chronic = 066 ugl (expressed as dissolved)
Step 2 Determine if there is reasonable potential (RP) for the discharge to exceed the criteria in the receiving water
To determine reasonable potential the maximum projected receiving water concentration (Cd) is compared to the applicable water quality criterion If Cd exceeds the criterion then reasonable potential exists and a water quality-based effluent limit is established Since the cadmium criteria is expressed as dissolved and a mixing zone is allowed Cd is determined with Equation 3
Cd = translator x (Ce x Qe) + [Cu x (Qu x MZ)] (Equation 3) Qe + (Qu x MZ)
The values for the parameters in the above equation are
translator = the water quality criteria conversion factor is used as the translator (see page C-7) The conversion factors for cadmium are based on hardness and calculated according to the equations shown in Table C-3
The hardness applicable to Outfall 001 for the low flow tier is 85 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (85) = 0951 chronic conversion factor = 1101672 - (0041838) ln (85) = 0916
The hardness applicable to Outfall 001 under the high flow tier is 55 mgl CaCO3 (see footnotes of Table C-4) The conversion factors based on this hardness are
acute conversion factor = 1136672 - (0041838) ln (55) = 0969 chronic conversion factor = 1101672 - (0041838) ln (55) = 0934
D-2
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 54: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/54.jpg)
Ce = maximum projected effluent concentration This is determined via Equation 5
Ce = (max measured effluent concentration) x RPM (Equation 5)
Since cadmium has a technology-based effluent limitation the maximum technology-based effluent limitation (100 ugl) is used as the maximum effluent concentration and the RPM is 1 (see Table C-8 and footnotes 3 and 5 of that table) Therefore Ce is calculated as
Ce = (100 ugl) x 1 = 100 ugl
Cu = upstream receiving water concentration = 007 ugl dissolved (see Table C-8)
Qu = upstream receiving water flow (see Table C-5) for low flow tier = 158 cfs for comparison to acute aquatic life criterion
= 205 cfs for comparison to chronic aquatic life criterion for high flow tier = 7 cfs for all criteria
Qe = effluent flow (see Table C-6) = 0023 cfs for the low flow tier = 0645 cfs for the high flow tier
MZ = mixing zone (see Table C-7) = 025 for the low flow tier = 050 for the high flow tier
Now plug the above values into Equation 3 and solve
For the low flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0951)(100)(0023) + (007) (158)(025) = 53 ugl 0023 + (158)(025)
Since the maximum projected receiving water concentration (Cd = 53 ugl) exceeds the acute aquatic life criterion (31 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0916) (100)(0023) + (007)(205)(025) = 40 ugl 0023 + (205)(025)
D-3
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 55: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/55.jpg)
Since Cd exceeds the chronic aquatic life criterion (091 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
For the high flow tier
Determine the reasonable potential to exceed acute aquatic life criterion
Cd = (0969)(100)(0645) + (007) (7)(050) = 15 ugl 0645 + (7)(050)
Since the Cd exceeds the acute aquatic life criterion (19 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
Determination of reasonable potential to exceed chronic aquatic life criterion
Cd = (0934) (100)(0645) + (007)(7)(050) = 15 ugl 0645 + (7)(050)
Since Cd exceeds the chronic aquatic life criterion (066 ugl) there is reasonable potential for the effluent to cause an exceedence to the water quality standard and a water quality-based effluent limit is required (see Table C-12)
NOTE If reasonable potential exists to exceed any one of the criteria for a particular parameter then water-quality based effluent limits are required for that parameter
Step 3 Since there is reasonable potential determine the wasteload allocation (WLAs)
Since the applicable criteria are expressed as dissolved the WLAs for cadmium in Outfall 001 are calculated using Equation 7
WLA = criterion x [Qe + (Qu x MZ)] - (Cu x Qu x MZ) (Equation 7) Qe x translator
The variables in the WLA equation have already been defined in Steps 1 and 2 Plugging these into Equation 7 and solving
For the low flow tier
Determination of the WLA for protection of acute aquatic life
D-4
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 56: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/56.jpg)
WLAacute = (31)[0023 + (158)(025)] - (007)(158)(025) = 580 ugl (0023) (0951)
Determination of the WLA for protection of chronic aquatic life
WLAchronic = (091)[0023 + (205)(025)] - (007)(205)(025) = 214 ugl (0023) (0916)
These WLAs are shown in Table C-16
For the high flow tier
Determination of the WLA for protection of acute aquatic life
WLAacute = (19)[0645 + (7)(050)] - (007)(7)(050) = 122 ugl (0645) (0969)
Determination of WLA for protection of chronic aquatic life
WLAchronic = (066)[0645 + (7)(050)] - (007)(7)(050) = 413 ugl (0645) (0934)
These WLAs are shown in Table C-17
Step 4a Develop Long-term Average Concentrations (LTAs) based on the WLAs
Effluent limits are developed by converting the aquatic life WLAs to long-term average concentrations (LTAs) The most stringent of the acute or chronic LTA is then used to develop the effluent limits The aquatic life WLAs are converted to long-term average concentrations (LTAs) using Equation 10
LTA = WLA x exp[05Fsup2 - zF] (Equation 10) where
z = 2326 for 99th percentile probability basis (per the TSD) CV = 06 (see Table C-8) for acute criteria Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075 for chronic criteria Fsup2 = ln(CVsup24 + 1) = ln (0624 + 1) = 00862
Plugging the above values and the WLAs from step 3 into Equation 10 and solving
For the low flow tier
D-5
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 57: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/57.jpg)
LTAacute = (580) x exp [05(03075) - (2326)(05545)] = 186 ugl
LTAchronic = (214) x exp [05(00862) - (2326)(02936)] = 113 ugl
These LTA concentrations are also shown in Table C-16 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
For the high flow tier
LTAacute = (122) x exp [05(03075) - (2326)(05545)] = 392 ugl
LTAchronic = (413) x exp [05(00862) - (2326)(02936)] = 218 ugl
These LTA concentrations are also shown in Table C-17 Since the LTA concentration based on the chronic criterion is more stringent than the LTA based on the acute criterion the chronic LTA is used to derive the aquatic life effluent limits for cadmium (see Step 4b below)
Step 4b Develop Effluent Limits Based on the LTA
The most stringent LTA concentration for each flow condition is converted to a maximum daily limit (MDL) and an average monthly limit (AML) via Equation 11
MDL AML = LTA x exp[zF-05Fsup2] (Equation 11)
where for the MDL z = 2326 for 99th percentile probability basis (per the TSD)
Fsup2 = ln(CVsup2 + 1) = ln (062 + 1) = 03075
for the AML z = 1645 for 95th percentile probability basis (per the TSD) Fsup2 = ln(CVsup2n + 1) = ln (0621 + 1) = 03075
since n = number of samples per month = 1 (monthly monitoring for cadmium in Outfall 001)
Substituting the above values and the lowest LTA concentrations from Step 4a into Equation 11 and solving
D-6
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 58: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/58.jpg)
For the low flow tier
MDL = (113) exp [(2326)(05545) - 05 (03075)] = 35 ugl
AML = (113) exp [(1645)(05545) - 05 (03075)] = 24 ugl
For the high flow tier
MDL = (218) exp [(2326)(05545) - 05 (03075)] = 68 ugl
AML = (218) exp [(1645)(05545) - 05 (03075)] = 47 ugl
These are the cadmium effluent limits for Outfall 001 in the draft permit (see also Tables C-16 and C-17)
D-7
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
![Page 59: The U.S. Environmental Protection Agency (EPA) Proposes to ... · Technical Contact: Patty McGrath, (206) 553-0979 1-800-424-4372 (within Region 10) mcgrath.patricia@epa.gov The U.S](https://reader035.vdocuments.us/reader035/viewer/2022081611/5f0318ee7e708231d4078585/html5/thumbnails/59.jpg)
APPENDIX E - ENDANGERED SPECIES ACT
As discussed in Section VIIIA of the fact sheet Section 7 of the Endangered Species Act requires federal agencies to consult with the National Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) regarding potential affects a federal action may have on threatened and endangered species In response to a request for a list of threatened and endangered species in the vicinity of the discharge the USFWS identified the following federally-listed species in a letter dated October 15 1999 The species denoted by a are under the jurisdiction of NMFS
Endangered Species Gray Wolf (Canis lupus) - experimental Sockeye salmon (Oncorhynchus nerka)
Threatened Species Bald Eagle (Haliaeetus leucocephalus) Springsummer and fall chinook salmon (Oncorhynchus tshawytscha) Steelhead trout (Oncorhynchus mykiss) Bull Trout (Salvelinus confluentus) Utersquo ladies-tresses (Spiranthes diluvialis)
Proposed Threatened Species Lynx (Lynx canadensis)
In addition to these species the USFWS has listed two species of concern wolverine (Gulo gulo luscus) and white sturgeon (Accipenser gentilis)
EPA is currently undergoing informal consultation with the NMFS and USFWS As part of the consultation EPA is preparing a Biological Evaluation (BE) to evaluate the potential impacts of the NPDES discharge on the endangered and threatened species If the consultation results in reasonable and prudent alternatives or measures that require more stringent permit conditions EPA will incorporate those conditions into the final permit
APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002
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APPENDIX F - REFERENCES
EPA 1988 NPDES Permit No ID-002540-2 Issued June 30 1988
EPA 1991 Technical Support Document for Water Quality-based Toxics Control Office of Water Enforcement and Permits Office of Water Regulations and Standards Washington DC March 1991 EPA5052-90-001
EPA 1996a EPA Region 10 Guidance For WQBELs Below Analytical DetectionQuantitation Level NPDES Permits Unit EPA Region 10 Seattle WA March 1996
EPA 1996b The Metals Translator Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion EPA 823-B-96-007 June 1996
IDEQ 2000 Idaho Division of Environmental Quality April 26 2000 Draft Mixing Zone Determination and Proposed Authorization for New Discharges into Special Resource Waters Thompson Creek Mine NPDES No ID 002540-2
TCMC 1992 Thompson Creek Mining Company September 15 1992 NPDES Permit Application for Outfalls 001-004
TCMC 1993 Thompson Creek Mining Company September 2 1993 NPDES Permit Application for Outfall 005
TCMC 1998 Thompson Creek Mining Company February 1998 Supplemental Plan of Operations for the Cyprus Thompson Creek Project
TCMC 1999a Thompson Creek Mining Company June 1999 Consolidated Environmental Monitoring Program and SPOO Monitoring Plan prepared by EnviroNet Inc
TCMC 1999b Thompson Creek Mining Company September 1 1999 Additional application Materials and Comments Regarding Renewal of the NPDES Permit for the Thompson Creek Mine
TCMC 1999c Thompson Creek Mining Company September 21 1999 Information for the Renewal of the Thompson Creek Mine NPDES Permit
TCMC 1999d Thompson Creek Mining Company November 15 1999 Thompson Creek Water and Discharge Modeling Using 1981-99 Hydrology Database prepared by EnviroNet Inc
TCMC 2000 Thompson Creek Mining Company February 22 2000 Letter to Patty McGrath EPA and Modified NPDES Permit Application for Outfalls 001 and 002